RECORD OF DECISION AMENDMENT Record of Decision (ROD) Amendment documents the U.S. Environmental...

RECORD OF DECISION AMENDMENT

Vineland Chemical Company Superfund Site Cumberland County, New Jersey

Operable Unit 3: Exposed Sediment/Soil of the Blackwater Branch Floodplain

United States Environmental Protection Agency Region 2

New York, New York September 2016

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DECLARATION STATEMENT RECORD OF DECISION AMENDMENT

SITE NAME AND LOCATION

Vineland Chemical Company Superfund Site Cumberland County, New Jersey.

Superfund Site Identification Number: NJD002385664 Operable Unit 3 – Exposed Sediment/Soil of the Blackwater Branch Floodplain

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) Amendment documents the U.S. Environmental Protection Agency’s (EPA) selection of a change in the remedy for the River Areas Sediment Operable Unit 3 (OU3) portion of the remedy which was originally selected for the Vineland Chemical Company Superfund Site (site) in a 1989 ROD. This ROD Amendment applies specifically to the exposed sediment/soil of the Blackwater Branch floodplain. The amended remedy is an interim action that will be revisited at a later date as additional knowledge is gained about conditions in the floodplain and the long-term effectiveness of the interim remedial actions selected in this ROD Amendment. The original remedy was, and this ROD Amendment remedy is, chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §§ 9601-9675, and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. Part 300. This decision document explains the factual and legal basis for selecting a remedy to address contamination at the site. The attached index (see Appendix III) identifies the items that comprise the Administrative Record upon which the amended remedy is based.

The New Jersey Department of Environmental Protection (NJDEP) was consulted on the proposed amended remedy in accordance with Section 121(f) of CERCLA, 42 U.S.C. § 9621(f), and NJDEP concurs with the amended remedy (see Appendix IV).

RATIONALE FOR AMENDMENT

The 1989 ROD selected the excavation and treatment of the exposed arsenic-contaminated sediment in the Blackwater Branch floodplain. This ROD Amendment changes this portion of the response action to implementation of in-situ (in-place) treatment technologies to prevent recontamination of the exposed sediment/soil, excavation of localized areas of sediment/soil in the Blackwater Branch floodplain that have significantly elevated concentrations of contaminants, and performance monitoring to assure the remedy is effective and to assess the need for additional in-situ treatment and/or excavation. This amended remedy is necessary as sediment sampling conducted between 2010 and 2015 demonstrated that groundwater discharging to the Blackwater Branch floodplain is recontaminating the sediment/soil in certain areas. A subsequent Remedial System Evaluation of the groundwater extraction and treatment system determined that in-situ treatment can immobilize arsenic in soil before it reaches the

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Blackwater Branch floodplain. Based on this, EPA began implementation of a bench scale study and pilot testing program to evaluate the effectiveness of in-situ remediation technologies to prevent recontamination of the floodplain, and this ROD Amendment is based on the findings of the pilot study and EPA’s general knowledge of the site. ASSESSMENT OF THE SITE Actual or threatened releases of hazardous substances from the site, if not addressed by implementing the response action selected in this ROD Amendment, may present an imminent and substantial endangerment to public health, welfare or the environment. DESCRIPTION OF THE SELECTED REMEDY AS AMENDED The selected remedy described in this document addresses a discrete portion of OU3 of the site involving exposed sediment/soil of the Blackwater Branch floodplain near the former Vineland Chemical Company property on East Mill Road in the City of Vineland, Cumberland County, New Jersey. This is one of four remedial phases, or operable units, for the site. OU1 addressed the control of source material at the former Vineland Chemical Company plant site. OU2 addresses the management of the migration of contamination in groundwater; long-term operation and maintenance of the groundwater extraction and treatment system for this portion of the remedy is ongoing. OU3 addresses contamination associated with the sediment/soil in the river areas, including the Maurice River, the Blackwater Branch of the Maurice River and their associated floodplains. OU4 relates to Union Lake, an 870-acre impoundment on the Maurice River. Pursuant to the 1989 ROD, EPA excavated the exposed sediment/soil of the Blackwater Branch floodplain, treated the sediment/soil through water wash extraction, and placed the treated material back in the excavated portions of the floodplain. The sludge from the treatment process was transported off-site for proper disposal, and the work was initiated after the groundwater (OU2) portion of the remedy was operating. The groundwater remedy began operation in the summer of 2001 and the floodplain excavation and treatment work was completed in December 2012. However, monitoring since that time has shown that certain areas of exposed sediment/soil of the Blackwater Branch floodplain have become recontaminated with arsenic above the cleanup goals identified in the 1989 ROD due to arsenic in groundwater reaching the sediment/soil during the ongoing implementation of the OU2 remedy. The major components of this ROD Amendment include the following:

Installation of in-situ treatment technologies to prevent recontamination of the exposed

sediment/soil to concentrations above remediation goals. Hot-spot excavations to remove exposed sediment/soil in the Blackwater Branch

floodplain with contaminant concentrations above remediation goals. Performance monitoring to assure the remedy is effective and assess the need for

additional in-situ treatment and/or excavation.

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The in-situ technology used may vary across the affected areas and will depend on the geochemistry and subsurface conditions in each particular location. Examples of such technologies include air sparging in iron rich groundwater environments and iron chloride injection in addition to air sparging or peroxide injection in iron poor groundwater environments. In-situ technologies may also include pH adjustments and/or the installation reactive barriers. The in-situ treatment technology appropriate for each area of the site will be determined after further studies during remedial design.

In addition, the need for excavation of the exposed sediment/soil before and/or after in-situ treatment for each area of the site will be determined during the remedial design and further refined during implementation of the remedial action through performance monitoring.

This is considered an interim remedial action as it will be revisited at a future date as additional knowledge is gained about conditions in the sediment/soil and once the amended remedy’s long-term effectiveness as a part of the remedy for all operable units of the site can be evaluated.

The environmental benefits of the amended remedy may be enhanced by consideration, during the remedy design or implementation, of technologies and practices that are sustainable in accordance with EPA Region 2’s Clean and Green Energy Policy.

The estimated present-worth cost of the selected remedy is $14,897,663.

DECLARATION OF STATUTORY DETERMINATIONS

The selected amended remedy meets the requirements for remedial actions set forth in CERCLA Section121, 42 U.S.C. § 9621, because it: 1) is protective of human health and the environment; 2) meets a level or standard of control of the hazardous substances, pollutants and contaminantswhich at least attains the legally applicable or relevant and appropriate requirements under federal and state laws; 3) is cost-effective; and 4) utilizes permanent solutions and alternative treatments (or resource recovery) technologies to the maximum extent practicable. In addition, Section 121 of CERCLA includes a preference for remedies that employ treatment that permanently and significantly reduce the volume, toxicity or mobility of hazardous substances as a principal element (or requires a justification for not satisfying the preference). One of the main components of the selected remedy involves in-situ treatment that will reduce the mobility of contamination.

While this amended remedy will ultimately result in reduction in mobility of contaminant levels in sediment/soil and prevent recontamination, the remedy will take longer than five years to implement. As a result, the site will be reviewed at least once every five years until such time as remedial action objectives (RAOs) and remediation goals are attained and human health and the environment are protected under unrestricted site use.

This interim action is protective of human health and the environment and is intended to provide adequate protection until EPA evaluates its long-term effectiveness at a future date.

ROD AMENDMENT DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this ROD Amendment. Additional information can be found in the Administrative Record for the site.

• Chemicals of concern and their respective concentrations may be found in the "Remedial Action Objectives" section.

• Baseline risk represented by the chemicals of concern may be found in the "Updated Risk Assessments" section.

• A discussion of remediation goals may be found in the "Remedial Action Objectives" section.

• Estimated capital, annual operation and maintenance (O&M) and total present w~rth costs are discussed in the "Description of Alternatives for ROD Amendment" section.

• Key factors that led to selecting the remedy (i.e., how the selected remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision) may be found in the "Comparative Analysis of Alternatives for ROD Amendment" and "Statutory Determinations" sections.

Walter E. Mugdan, Director Emergency & Remedial Response Division EPA - Region 2

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DECISION SUMMARY

Operable Unit 3: Exposed Sediment/Soil of the Blackwater Branch Floodplain

Vineland Chemical Company Site Cumberland County, New Jersey

United States Environmental Protection Agency Region 2

New York, New York September 2016

TABLE OF CONTENTS PAGE

1.0 INTRODUCTION TO SITE AND STATEMENT OF PURPOSE .................................... 1

1.1 Site Name, Location and Description ..................................................................... 1

1.2 Lead and Support Agencies .................................................................................... 2

1.3 Statement of Purpose .............................................................................................. 2

1.4 Community Participation/Availability of Documents ............................................ 2

2.0 SITE HISTORY AND CONTAMINATION, AND 1989 ROD SELECTED REMEDY . 3

2.1 Site History and Contamination .............................................................................. 3

2.2 Original (1989) ROD Selected Remedy ................................................................. 4

2.3 Implementation of the 1989 ROD Selected Remedy for OU3 ............................... 6

3.0 BASIS FOR THE ROD AMENDMENT ............................................................................ 7

3.1 Sediment Sampling ................................................................................................. 8

3.2 Remedial System Evaluation (2011) ...................................................................... 9

3.3 Bench Scale Studies ................................................................................................ 9

3.4 Updated Risk Assessments ..................................................................................... 9

4.0 REMEDIAL ACTION OBJECTIVES .............................................................................. 11

5.0 DESCRIPTION OF ALTERNATIVES FOR ROD AMENDMENT ............................... 12

6.0 COMPARATIVE ANALYSIS OF ALTERNATIVES FOR ROD AMENDMENT........ 14

7.0 SELECTED AMENDED REMEDY ................................................................................. 18

8.0 STATUTORY DETERMINATIONS ............................................................................... 19

8.1 Protection of Human Health and the Environment ............................................... 20

8.2 Compliance with ARARs ..................................................................................... 20

8.3 Cost-Effectiveness ................................................................................................ 20

8.4 Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery) Technologies to Maximum Extent Practicable ................... 21

8.5 Preference for Treatment as a Principal Element ................................................. 21

8.6 Five-Year Review Requirements .......................................................................... 21

9.0 DOCUMENTATION OF SIGNIFICANT CHANGES .................................................... 21

APPENDICES

APPENDIX I FIGURES APPENDIX II TABLES APPENDIX III ADMINISTRATIVE RECORD INDEX APPENDIX IV STATE LETTER APPENDIX V RESPONSIVENESS SUMMARY

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1.0 INTRODUCTION TO SITE AND STATEMENT OF PURPOSE

1.1 Site Name, Location and Description The Vineland Chemical Company Site (site), U.S. Environmental Protection Agency (EPA) Superfund Site Identification Number NJD002385664, is located in the City of Vineland, Cumberland County, New Jersey. The site is located in the northwestern portion of Vineland, which is in south central New Jersey, in an area of mixed industrial, low-density residential and agricultural properties (see Appendix I, Figures 1 and 2). The site is bordered to the north by other industrial properties and the Blackwater Branch, a perennial stream that flows westward to the Maurice River. The Blackwater Branch of the Maurice River flows northeast to southwest, in proximity to, and partially through, the site itself. A floodplain lies immediately adjacent to the Blackwater Branch along the entire length of the tributary extending to the Maurice River. The site is located in the Atlantic Coastal Plain physiographic province, which consists of a seaward-dipping wedge of unconsolidated sediment (sand, silt, clay, and gravel) that range in age from Cretaceous to Quaternary periods. Locally, the site is situated on a relatively level plain that slopes slightly from the southeast toward the northwest with topographic elevations that range from 65 to 75 feet above mean sea level. Groundwater levels vary seasonally at the site with an average of approximately 10 feet below ground surface (bgs), and a typical minimum and maximum of between 4 and 19 feet bgs. When the groundwater treatment plant is not in operation, groundwater south of the Blackwater Branch moves in an east to west direction with groundwater discharging at several locations along Blackwater Branch. Under pumping conditions, the direction of flow is somewhat altered to a more southeast to northwest flow direction south of Blackwater Branch, and a northeast to southwest flow direction north of Blackwater Branch. Groundwater that is not captured by the recovery system discharges to Blackwater Branch. Due to the large area, the different media affected by contamination, and the complexity of multiple areas and varying land uses at the site, EPA is addressing the cleanup of the site in several phases, or operable units (OUs). A Record of Decision (ROD) signed on September 28, 1989 divided the site into four OUs (Appendix I, Figure 3), and selected remedies to address each of the operable units. Operable Unit 1 (OU1) consisted of the control of source material at the former Vineland Chemical Company plant site. To address arsenic-contaminated soil, EPA constructed a soil washing facility that processed up to 70 tons of excavated soil per hour. The facility processed over 400,000 tons of arsenic-contaminated soil and sediment, and the remaining waste was disposed of at a permitted off-site disposal facility. The soil remedy was completed in December 2014. OU2 relates to management of the migration of groundwater contamination. To address contaminated groundwater, EPA constructed a system to pump and treat about two million

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gallons of contaminated groundwater daily. Operation of the facility began in the spring of 2000 and is ongoing. The pump-and-treat operation is capturing the majority of the flow of arsenic-contaminated groundwater from the plant site, and removing the arsenic through treatment. The treated groundwater continues to meet the site’s cleanup goal. Operation of the pump-and-treat system was transferred to NJDEP in October 2014.

OU3 relates to contamination associated with the sediment/soil in the river areas, including the Maurice River, the Blackwater Branch of the Maurice River and their associated floodplains. To address the river areas, the 1989 ROD selected excavation/dredging of the Blackwater Branch soil and sediment, treatment of this material via water wash extraction, and placement of the treated material back in the excavated areas. Following this and implementation of the OU2 remedy, a three year monitoring period was to be initiated to see if natural river flushing would effectively address remaining contamination in the Maurice River. The excavation/dredging of the Blackwater Branch and its associated floodplain was completed in December 2012 and the three year monitoring period ended in August 2014.

OU4 of the site relates to Union Lake, an 870-acre impoundment on the Maurice River. The interim remedy for OU4 will be initiated once the upstream remedial activities have been completed. The remediation of the sediment in Union Lake involves excavation of the arsenic-contaminated sediment at the periphery of the lake, once they have been exposed by lowering the lake’s water level. Sediment at the upper end of the lake above the submerged dam will be evaluated prior to dredging and an environmental assessment of the impact of dredging will be performed. Beach monitoring in Union Lake began in the early 2000s and will continue until it is concluded that there are no further unacceptable impacts to the lake. To date, no unacceptable risks to beach users have been identified.

1.2 Lead and Support Agencies

EPA is the lead agency and the NJDEP is the support agency.

1.3 Statement of Purpose

An amendment to the 1989 ROD is necessary because a fundamental change is being made to the portion of the OU3 remedy related to the exposed sediment/soil of the Blackwater Branch floodplain. This ROD Amendment documents the basis for this fundamental change. This ROD Amendment is issued in accordance with Section 117 of CERCLA and 40 CFR 300.435(c)(2)(ii) of the National Oil and Hazardous Substances Contingency Plan (NCP).

1.4 Community Participation/Availability of Documents

In compliance with Section 117 of CERCLA and NCP Section 300.435(c)(2)(ii), on July 22, 2016 EPA released the Proposed Plan for the amendment of the cleanup of the exposed sediment/soil of the Blackwater Branch floodplain and supporting documentation to the public for comments. EPA made these documents available to the public in the administrative record file maintained at the Vineland City Library, 1058 East Landis Avenue in Vineland, New Jersey and at the EPA Region 2 Superfund Records Center located at 290 Broadway, New York, New

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York (see Appendix III). The administrative record file is also available online at www.epa.gov/superfund/vineland-chemical. EPA published a notice of availability of these documents in the Press of Atlantic City newspaper on July 22, 2016. The public comment period lasted 30 days and closed on August 22, 2016.

A public meeting was held on August 8, 2016, at the Vineland City Hall, 640 E Wood Street in Vineland, New Jersey to inform local officials and interested citizens about the Superfund process, to review the completed and planned remedial activities at the site, and to respond to questions from area residents and other attendees. Comments that were received by EPA at the public meeting and in writing during the public comment period are included in the Responsiveness Summary (see Appendix V).

The ROD Amendment and supporting documentation will become part of the Administrative Record for the site, in accordance with NCP 40 C.F.R. § 300.825 (a)(2). The Administrative Record Index is presented in Appendix III to this ROD Amendment.

2.0 SITE HISTORY AND CONTAMINATION, AND 1989 ROD SELECTED REMEDY

2.1 Site History and Contamination

The Vineland Chemical Company operated from 1949 to 1994 and produced arsenical herbicides and fungicides. There were seventeen buildings on the plant site, some of which were used by the Vineland Chemical Company for various manufacturing purposes.

As early as 1966, the New Jersey Department of Health observed untreated wastewater being discharged into unlined lagoons at the site. This wastewater was contaminated with arsenic at concentrations up to 67,000 parts per billion (ppb). Waste salts containing 1-2 percent arsenic were stored outside in uncovered piles. Precipitation dissolved some of these salts and carried them into the groundwater and eventually into nearby surface water bodies. Contaminated sediment was mapped 1.5 miles downstream in Blackwater Branch to its confluence with the Maurice River and then 7.5 miles downstream to Union Lake.

Between 1975 and 1976, Vineland Chemical was "fixating" the waste salts for disposal at the Kin-Buc Landfill. The process involved mixing the dried salts with ferric chloride and soda ash, reportedly reducing the solubility. The process was stopped in 1976 when the Kin-Buc Landfill voluntarily stopped accepting all chemical wastes, including the fixated salts. The company then resumed stockpiling the untreated waste salts on the soil surface at the plant site.

A court order issued on January 26, 1977 required Vineland Chemical to containerize the waste salts located in chicken coops and piles, and then store the drums in a warehouse off-site. In June 1979, another court order was issued for the disposal of the stored drums in an approved landfill. Removal and disposal of these drums were not completed until June 30, 1982.

Aerial photographs provided by EPA's Environmental Photographic Information Center, as well as conversations with Vineland Chemical Company employees, indicated several possible

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locations of historic contamination. A cleared area in the southwest corner of the site was previously occupied by two chicken coops. Sometime between November 1975 and March 1979, both coops were destroyed. These coops were reportedly used to store process chemicals and/or waste in the 1970s. The materials stored in the coops may have percolated into the groundwater. Photographs showed many locations containing mounded material and/or drums. These were observed in the lagoon area and along the plant road. The floors of the manufacturing buildings may also have been leaking arsenic compounds into the underlying sands for years. The original floors of the buildings were brick and were reportedly in need of repair. When the bricks were removed, the underlying soil was said to have contained crystalline waste from previous spills. It is not known whether the soil was removed when the floors were replaced. In early 1992, EPA assessed the plant site conditions after being informed by the plant manager that the Vineland Chemical Company site would be abandoned. EPA found thousands of gallons of arsenic solutions stored in tanks and containers on the site. In June 1992, EPA secured the buildings and installed fences around soil areas containing high levels of arsenic. In addition, a fence was installed around the plant site to restrict trespassers. Removal of the hazardous materials stored in tanks and containers began in the fall of 1992. The company ceased operations, and the plant site buildings were abandoned in early 1994. The site was added to the EPA’s National Priorities List (NPL) in September 1984. A Remedial Investigation and Feasibility Study (RI/FS) was completed in 1989 to identify the types, quantities, and locations of contaminants, and to develop ways to correct the problems posed by the contaminants. Potentially responsible parties (PRPs) identified for the site include the Vineland Chemical Company and its owners. In 1994, the PRPs entered into a judicial consent decree with EPA, fully resolving their liability. The Vineland Chemical Company no longer exists and the owners of the site are deceased. 2.2 Original (1989) ROD Selected Remedy In September 1989, EPA issued a ROD for the entire site, with NJDEP concurrence. The major components of the 1989 ROD, as excerpted exactly from the Declaration Statement, are as follows: Operable Unit One (Plant Site Source Control)

In situ treatment, by flushing, of the arsenic-contaminated soil to reduce arsenic levels. Portions of the contaminated soil will be excavated and consolidated prior to the flushing action.

Plant site remediation also includes closure of the two lined surface impoundments in compliance with the Resource Conservation and Recovery Act (RCRA), and decontamination of the former chicken coop storage buildings.

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Operable Unit Two (Plant Site Management of Migration)

Removal of arsenic-contaminated groundwater through pumping, followed by on-sitetreatment and reinjection of the treated groundwater to the aquifer at the maximum ratepracticable. The remainder of the treated groundwater will be discharged to the MauriceRiver. A portion of the treated groundwater will also be used for the soil flushing actionin Operable Unit One. The arsenic-contaminated sludge from the groundwater treatmentprocess will be transported off-site for hazardous waste treatment and disposal. Thisaction will effectively eliminate the source of arsenic into the Maurice River system.

Operable Unit Three (River Areas Sediment)

Excavation and treatment of the exposed arsenic-contaminated sediment in theBlackwater Branch floodplain. Treatment will consist of a water wash extraction. Thecleaned sediment will be redeposited in the excavated portion of the floodplain. Thesludge from the extraction process will be transported off-site for hazardous wastetreatment and disposal. Remediation will begin after the contaminated groundwater flowinto the Blackwater Branch has been stopped.

Dredging/removal and treatment, by water wash extraction, of the submerged arsenic-contaminated sediment in the Blackwater Branch adjacent to and downstream of theVineland Chemical Company plant site. Prior to removing any sediment, anenvironmental assessment of the impact of dredging will be performed and aconfirmation made that this sediment is a source of contamination to the river system.The treated sediment will be redeposited on undeveloped areas of the Vineland ChemicalCompany plant site. The sludge from the extraction process will be transported off-sitefor hazardous waste treatment and disposal.

After stopping the flow of arsenic-contaminated groundwater from the VinelandChemical Company plant site, a three year period for natural river flushing will beimplemented. This will allow the submerged, arsenic-contaminated sediment in theMaurice River to be flushed clean through natural processes. If, after this period, thesubmerged sediment is no longer contaminated with arsenic above the action level, noremediation will be performed in the river. Similarly, if sediment contamination abovethe action level persists, but the observed or expected natural decontamination rate isconsistent with an acceptable public health risk, no remediation will be performed.However, if contamination above the action level persists in some locations and isexpected to remain at levels posing unacceptable health risks, those locations would beremediated.

Remediation of the submerged Maurice River sediment will be performed, as necessary,by dredging and treatment with a water wash extraction. However, prior to removing anysediment, an environmental assessment of the impacts of dredging will be made. Thetreated sediment will be deposited on undeveloped areas of the Vineland ChemicalCompany plant site. The sludge from the extraction process will be transported off-sitefor hazardous waste treatment and disposal.

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Operable Unit Four (Union Lake Sediment)

Removal and treatment of arsenic-contaminated sediment on the periphery of Union Lakewill be performed after the three year flushing period (if no remediation is performed inthe Maurice River) or after remediation of the Maurice River (if this is necessaryfollowing the flushing period). Verification sampling will be conducted prior toremediation to confirm the locations of sediment contaminated above the action level forarsenic along the periphery of Union Lake.

The arsenic-contaminated sediment on the periphery of Union Lake will be excavatedafter they are exposed by lowering the lake's water level. However, for the upper end ofthe lake above the submerged dam, prior to removing any sediment, an environmentalassessment of the impact of dredging will be performed. The sediment will be treated bywater wash extraction and the cleaned sediment returned to its approximate formerlocations in Union Lake. The sludge from the extraction process will be transported off-site for hazardous waste treatment and disposal.

This is an interim remedy, since arsenic-contaminated sediment above health-basedlevels will remain in Union Lake. Therefore, periodic reviews will be conducted todetermine whether contaminated sediment is redistributed, through natural processes, tothe cleaned areas.

EPA also issued two Explanations of Significant Differences (ESDs) for the site, one in 1997 and one it 2001. The basic rationale and effect of these ESDs are as follows:

1997 ESD: During the pre-design investigation phase, borings were advanced through thefloors of all the plant site buildings and paved areas. Samples were also collected frominside the buildings including the walls, floors, ceilings and equipment. Significantquantities of arsenic at elevated concentrations were discovered in some of the buildingsand in the soil at depths down to the water table. On June 26, 1997, EPA approved anESD which included the demolition and disposal of the plant site buildings and debris.The ESD also included an increase in volume of the contaminated plant site soil andchanges in the groundwater treatment plant size and treatment process.

2001 ESD: In August 2001, EPA changed the in-situ soil flushing remedy to ex-situ soilwashing, based on the results of treatability studies that concluded soil flushing was moreeffective at reducing arsenic concentrations to the clean-up goal of 20 mg/kg.

2.3 Implementation of the 1989 ROD Selected Remedy for OU3

The excavation and treatment of arsenic impacted sediment from the Blackwater Branch and its floodplain were carried out in four phases from 2006 through 2012. Phase 1 encompassed the area east of North Mill Road and adjacent to the chemical plant site. Phase 2 encompassed the area west of North Mill Road and east of Route 55. Phase 3 encompassed the area west of Route 55 and east of the Maurice River Parkway. Phase 4 encompassed the stream and floodplain west of the Maurice River Parkway to the Maurice River.

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In each phase, the Blackwater Branch was diverted to a clean location before excavation of the contaminated material was performed. Once material with arsenic concentrations exceeding 20 milligrams/kilogram (mg/kg), the value identified in the 1989 ROD, was removed and either treated via soil washing or disposed of off-site, the excavated area was backfilled with clean material and stream flow was restored to the re-constructed stream channel.

Soon after arsenic excavation in the floodplain of Phases 1 and 2 was completed in 2009, iron staining along the banks and within the Blackwater Branch was observed in certain locations. Sediment and seep water samples collected between 2010 and 2015 demonstrated that groundwater that is discharging to the Blackwater Branch in certain areas is recontaminating the sediment due to localized geochemical conditions that result in the dissolved arsenic precipitating out as the groundwater discharges into the branch sediment.

3.0 BASIS FOR THE ROD AMENDMENT

An Amendment to the 1989 ROD is necessary because a fundamental change to the OU3 remedy is needed. Since implementation of the original OU3 remedy, new information has been collected to support a change from the technology selected in the 1989 ROD to one that EPA anticipates will address the recontamination that is occurring in the Blackwater Branch sediment/soil.

This new information is summarized as follows and discussed in more detail below:

Sediment samples collected between 2010 and 2015 demonstrated that groundwater thatis discharging to the Blackwater Branch floodplain in certain areas is recontaminating thesediment/soil.

New information collected as part of a Remedial System Evaluation (RSE) of the pump-and-treat system completed in 2011 found that the system provided reasonably goodcontainment of the contaminated groundwater plume, but that concentration reductionrates had slowed to asymptotic conditions over the past 10 years. It was concluded thatdue to existing geochemical conditions, active in-situ treatment for arsenicimmobilization could play an important role in cost effectively containing thegroundwater plume and optimizing the remedial processes at the site.

Bench scale studies and pilot tests of in-situ treatment technologies have been conductedand are ongoing. Thus far, in-situ treatment has been shown to be effective in preventingrecontamination of the sediment/soil of the Blackwater Branch floodplain, and isexpected to be effective in other parts of the impacted floodplain.

An updated human health risk assessment was conducted, which concluded that theconcentrations of arsenic accumulating in the floodplain continue to be associated withunacceptable levels of risk. Likewise, an ecological screening assessment concluded thatarsenic is accumulating in the floodplain at concentrations that pose a potential risk toecological receptors.

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3.1 Sediment Sampling

Soon after arsenic excavation in the floodplain of Phases 1 and 2 was completed in 2009, iron staining along the banks and within the Blackwater Branch was observed in certain locations. Sediment and seep water samples taken at a few of these iron-stained locations were analyzed in 2010 to determine if these iron-stained sediment also contained arsenic. Phase 1 samples were taken after excavation, backfilling and flow had been restored to the channel. Phase 2 samples were collected after excavation and backfilling in the floodplain had occurred, but before flow was restored to the original creek channel.

The sediment samples that were co-located with the seep samples contained arsenic just above the floodplain sediment cleanup goal of 20 mg/kg as identified in the 1989 ROD. These results provided evidence that arsenic is seeping into the Blackwater Branch floodplain at some of the locations sampled even with the pump and treat system in operation, contaminating exposed sediment/soil by precipitating out once it discharges. The OU3 remedy was selected based on the assumption that groundwater discharging into the Blackwater Branch floodplain would not impact the exposed sediment/soil.

Further sampling of surface sediment was performed between 2011 and 2012 along Phases 2, 3 and 4, soon after stream restoration and prior to re-diverting the surface water back to the stream. Samples were biased toward the iron-stained sediment. Results indicated that arsenic in surface sediment samples accumulated soon after restoration and concentrations exceeded 20 mg/kg in exposed sediment/soil. Due to extensive arsenic exceedances along the Phase 4 segment of the Blackwater Branch, surface water was not re-diverted back to this section of the Blackwater Branch. The Blackwater Branch was eventually re-diverted back to a stream alignment that was similar to the original but followed an alternate path around the areas where the arsenic exceedances were encountered.

Additional sediment sampling was conducted in Phases 1 and 2 between 2013 and 2015. Samples were biased to locations that were iron-stained and were collected from floodplain areas as well as locations near the banks of the Blackwater Branch where sediment is likely to be exposed during periods of low water level conditions. During this time period, operation of the pump and treat system varied between full pumping, no pumping and partial pumping. Concentrations of arsenic in sediment samples exceeded 20 mg/kg while the pump and treat system was fully operational as well as when the pump and treat system was shut down.

The sediment samples collected between 2010 and 2015 demonstrated that groundwater that is discharging to the Blackwater Branch in certain areas is recontaminating the sediment due to localized geochemical conditions that result in the dissolved arsenic precipitating out as the groundwater discharges into the branch sediment. Over time, larger areas of sediment may become recontaminated. It should be noted that despite the elevated arsenic concentrations in the floodplain, surface water arsenic concentrations have not been found to be elevated.

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3.2 Remedial System Evaluation (2011) In 2011, EPA performed an optimization study to evaluate the efficiency of the pump-and-treat groundwater remediation system. Although this study was focused on OU2 (groundwater), it impacts OU3. The RSE focused on maximizing the efficiency of the pump-and-treat system, while maintaining protection of human health from exposure to site contaminants; expediting the cleanup; and identifying key steps to achieve the RAOs defined in the 1989 ROD. In the RSE it was recommended that due to existing geochemical conditions, active in-situ treatment for arsenic immobilization could play an important role in cost effectively containing the groundwater plume. 3.3 Bench Scale Studies Once EPA determined that implementation of the original OU3 remedy would not prevent recontamination of the floodplain sediment/soil and the RSE recommended immobilization as a potential technology for the site, preliminary bench scale testing was conducted to evaluate the viability of in-situ treatment as a method of controlling recontamination. In-situ treatments evaluated at the bench scale focused on creating conditions for which the accumulation of arsenic in sediment would be unfavorable either by reducing the movement of arsenic to the sediment/soil of the floodplain or by reducing the availability of areas onto which arsenic can accumulate through bonding with the sediment. Results of the bench scale studies indicated that several methods of in-situ treatment can reduce arsenic accumulation in sediment/soil so that concentrations in the Blackwater Branch floodplain would remain below cleanup goals. These methods include in-situ treatment with oxygen (such as by air sparging or the use of peroxide), in-situ treatment with iron, and/or in-situ pH adjustment. In 2015, pilot testing of in-situ treatment options was initiated, and the preliminary results of this testing are favorable. Because the results show that the in-situ treatment is working, the pilot study will continue and will remain operational until the amended remedy is implemented. 3.4 Updated Risk Assessments Human Health Risk Assessment As part of the July 2016 Focused Feasibility Study (FFS) that supports this ROD Amendment, a four-step human health risk assessment process was used for assessing site-related cancer risks and noncancer health hazards from exposure to arsenic in the exposed sediment/soil of the Blackwater Branch floodplain. The four-step process is comprised of:

Hazard Identification – this step identifies the chemicals of concern (COCs) at a site based on several factors such as toxicity, frequency of occurrence, and concentration;

Exposure Assessment – this step estimates the magnitude of actual and/or potential

human exposures, the frequency and duration of these exposures, and the pathways by

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which humans are potentially exposed (i.e., ingestion and dermal contact with contaminated soil);

Toxicity Assessment – this step identifies the types of adverse health effects associatedwith chemical exposures, and the relationship between magnitude of exposure (dose) andseverity of adverse effects (response); and

Risk Characterization – this step summarizes and combines outputs of the exposure andtoxicity assessments to provide a quantitative assessment of site-related risks. During thisstep, contaminants with concentrations that exceed federal Superfund guidelines foracceptable exposure are identified. These guidelines are 10-4 to 10-6, or one-in-ten-thousand to one-in-a-million excess occurrences for cancer, and a Hazard Index (HI) ofgreater than 1 for noncancer health hazards. Contaminants with concentrations thatexceed these guidelines are then considered COCs for a site and are typically those thatwill require remediation. The uncertainties associated with the risk calculations are alsoevaluated under this step.

Three separate areas with contamination in the floodplain of the Blackwater Branch were identified with unique geochemical conditions and were designated Areas A, B, and C (Appendix I, Figure 4). The maximum detected arsenic concentrations in all three of these areas of the Blackwater Branch floodplain exceed the site cleanup level of 20 mg/kg for arsenic in exposed sediment/soil by an order of magnitude or more. Additionally, the 2016 supplemental risk assessment concluded that the maximum detected arsenic concentrations in these areas are greater than the health-based regional screening level (RSL) for arsenic, which indicates the potential for unacceptable risk and adverse health effects from recreational exposure to exposed Blackwater Branch sediment. The RSL uses standardized equations that combine exposure information and assumptions with available toxicity data.

A semi-quantitative screening evaluation was conducted for Area C of the Blackwater Branch floodplain. The risk evaluation for Area C is summarized in Appendix II, Tables 1 through 6. The results indicate that the current remedy is not protective of human health for a future recreator. The estimated cancer risk for a child and adult recreator utilizing the Blackwater Branch in Area C would equal 3 x10-4, exceeding EPA’s acceptable risk range of 10-6 to 10-4. The noncancer hazard estimates for a child and adult recreator in Area C are 5 and 0.5, respectively, with the child recreator exceeding EPA’s noncancer hazard index of 1. These conclusions support those in the 1989 HHRA. Any current site user (e.g., treatment plant worker or trespasser) would have less frequent exposures, and thereby lower risks, than these future receptors.

Ecological Risk Assessment

A different approach was used in evaluating ecological risk associated with contamination in the exposed sediment/soil of the Blackwater Branch floodplain in comparison to the evaluation of human health risks. As is stated above, maximum concentrations of arsenic in all three areas of the Blackwater Branch floodplain exceed the site 1989 cleanup level of 20 mg/kg for arsenic in exposed sediment/soil by an order of magnitude or more. As such, an evaluation was conducted

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to determine whether cleanup of the floodplain to concentrations below the 1989 ROD goal would be protective of the environment.

The floodplain soil is considered to be representative of a terrestrial environment, thus concentrations of arsenic were compared to EPA’s Ecological Soil Screening Level (Eco-SSLs), which are concentrations of contaminants in soil that are protective of ecological receptors that commonly come into contact with and/or consume biota that live in or on soil. As such, these values are presumed to provide adequate protection of terrestrial avian and mammalian receptors. The EPA Eco SSLs for arsenic are 18 mg/kg for plants, 43 mg/kg for avian receptors and 46 mg/kg for mammalian receptors.

Comparison of these screening levels to the 1989 ROD goal of 20 mg/kg for arsenic shows that this value is protective for avian and mammalian receptors. The only ecological value that is lower than 20 mg/kg is the value that was derived to be protective to plants (18 mg/kg). However, 18 mg/kg is below what is considered background for arsenic (20 mg/kg in 1989, 19 mg/kg currently) and is not considered achievable under site-specific conditions. Conversely, since concentrations above 46 mg/kg are present, this review shows that there is a potential risk to ecological receptors.

Conclusion

Based on the new information summarized above, the current remedy has not effectively mitigated the risks to recreators and ecological receptors, and further action is warranted to protect human health and the environment. As a result, new alternatives to address the exposed sediment/soil of the Blackwater Branch floodplain portion of OU3 of the site were evaluated in an FFS.

4.0 REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These objectives are based on available information and standards such as applicable or relevant and appropriate requirements (ARARs), to-be-considered (TBC) guidance and site-specific risk-based levels and background (i.e., reference area) concentrations. The 1989 ROD identified the following RAO for the sediment in OU3:

Minimize public exposure, either through containment, removal, or institutional controls,for those areas with unacceptably high sediment arsenic concentrations.

This overall RAO for OU3 remains in effect. The specific RAOs for the selected remedy described in this ROD Amendment are:

Reduce concentrations of arsenic in the exposed sediment/soil in the Blackwater Branchfloodplain to below acceptable levels of risk.

Prevent recontamination of exposed sediment/soil of the Blackwater Branch floodplainfrom site-related groundwater contamination.

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As additional knowledge is gained about conditions in the sediment/soil in this area, and the long-term effectiveness of the amended remedy is evaluated, EPA’s expectation is that the remedy described in this ROD Amendment will be revisited at a future date. Therefore, this action is considered an interim remedial action. Remediation Goal EPA has adopted the preliminary remediation goal identified in the Proposed Plan as the final Remediation Goal (RG) for OU3 of the site. The soil remediation goal for arsenic, the COC at the Site, is consistent with New Jersey Residential Direct Contact Soil Remediation Standard (RDCSRS). The remediation goal for OU3 is as follows:

Constituent in Soil Cleanup Goal (mg/kg) Arsenic 19

The 1989 ROD identified a Remediation Goal of 20 mg/kg for arsenic in exposed sediment/soil of the Blackwater Branch floodplain. Since then, the state of New Jersey has conducted a much more robust study of statewide levels of arsenic in soil, and from this study a statewide concentration of 19 mg/kg has been established. EPA has evaluated the protectiveness of 19 mg/kg and the Remediation Goal for arsenic in the exposed sediment/soil has been modified to meet the current New Jersey RDCSRS. 5.0 DESCRIPTION OF ALTERNATIVES FOR ROD AMENDMENT The remedial alternatives considered for this ROD Amendment are summarized below. Capital costs are those expenditures that are required to construct a remedial alternative. Operation and maintenance (O&M) costs are those post-construction costs necessary to ensure or verify the continued effectiveness of a remedial alternative and are estimated on an annual basis. Present worth is the amount of money which, if invested in the current year, would be sufficient to cover all the costs over time associated with a project, calculated using a discount rate of seven percent. Since these are considered interim remedies, a 10-year time interval was evaluated. Construction time is the time required to construct and implement the alternative and does not include the time required to design the remedy or procure contracts for design and construction. Detailed information regarding the alternatives can be found in the 2016 FFS. Alternative 1 – No Further Action

The NCP requires that a “No Action” alternative be evaluated to establish a baseline for comparison with other remedial alternatives. Under this alternative, no further action would be implemented, and the current status of the site would remain unchanged. A Classification Exception Area for the site already exists to restrict use of groundwater. Signs are posted in accessible areas of Blackwater Branch and the Maurice River advising the public that sediment is contaminated with arsenic and there are risks associated with prolonged exposure of arsenic. With the exception of the existing security fences, engineering controls would not be implemented to prevent site access or exposure to site contaminants.

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Total Capital Cost: $0 Annual O&M: $0 Present Worth Cost: $0 Construction Timeframe: 0 years

Alternative 2 – Ongoing Hot Spot Excavation

This alternative consists of periodic excavation and off-site disposal of the exposed sediment/soil of the Blackwater Branch floodplain as the arsenic concentrations exceed the remediation goals. Excavated sediment/soil would be transported and disposed of off-site.

The sediment/soil would be sampled to determine if they need to be disposed of as either hazardous waste or non-hazardous waste. Treatment of sediment/soil, if needed, would be conducted at and by the approved disposal facility.

Total Capital Cost: $1,160,646 Annual O&M: $4,642,584 Present Worth Cost: $33,768,213 Construction Time Frame: Constant over 10 years

Alternative 3 – In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring

This alternative consists of installation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil to concentrations above remediation goals, hot-spot excavations to remove exposed sediment/soil in the Blackwater Branch floodplain above remediation goals, and performance monitoring to assure the remedy is effective and assess the need for additional in-situ treatment and/or excavation. In-situ technologies are those technologies that are implemented in place, rather than removing the contamination and treating it.

The in-situ technology used may vary across the site and will depend on the geochemistry and subsurface conditions in each particular location. Examples of such technologies include air sparging in iron rich groundwater environments and iron chloride injection, in addition to air sparging or peroxide injection, in iron poor groundwater environments. In-situ technologies may also include pH adjustments and/or the installation of material into the ground which will intercept the groundwater flow and passively capture the contamination, also known as ‘reactive barriers’. Final selection of the in-situ treatment technology appropriate for each area of the site will be made after further studies during remedial design.

In addition, the need for excavation of the exposed sediment/soil before and/or after in-situ treatment for each area of the site will be determined during the remedial design and further refined during implementation of the remedial action through performance monitoring.

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Total Capital Cost: $9,988,488 Annual O&M: $745,569 Present Worth Cost: $14,897,663 Construction Time Frame: 1 year

Change in Expected Outcome

Both the 1989 ROD and the ROD Amendment have the same objective for OU3 sediment/soil of the Blackwater Branch floodplain: reducing contaminant levels to below federal and state standards. As a result, there is no change to the expected outcome that will result from this ROD Amendment. However, the amended remedy will remove the recontaminated exposed sediment/soil and prevent any more recontamination of the exposed sediment/soil in the Blackwater Branch and its floodplain so that the contamination levels will remain below federal and state standards.

The 1989 ROD identified a Remediation Goal of 20 mg/kg for arsenic in exposed sediment/soil in the Blackwater Branch floodplain. However the Remediation Goal for arsenic in the exposed sediment/soil has been modified to meet the current New Jersey RDCSRS of 19 mg/kg.

6.0 COMPARATIVE ANALYSIS OF ALTERNATIVES FOR ROD AMENDMENT

In selecting a remedy for a site, EPA considers the factors set forth in Section 121 of CERCLA 42 U.S.C. § 9621, and conducts a detailed analysis of the viable remedial alternatives pursuant to Section 300.430(e)(9) of the NCP, 40 C.F.R § 300.430(e)(9), EPA’s Guidance for Conducting Remedial Investigations and Feasibility Studies, OSWER Directive 9355.3-01, and EPA’s A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents, OSWER 9200.1-23.P. The detailed analysis consists of an assessment of the individual alternatives against each of the nine evaluation criteria at 40 C.F.R. § 300.430(e)(9)(iii) and a comparative analysis focusing upon the relative performance of each alternative against those criteria.

A comparative analysis of these alternatives based upon the nine evaluation criteria noted herein follows.

Threshold Criteria – The first two criteria are known as “threshold criteria” because they are the minimum requirements that each response measure must meet in order to be eligible for selection as a remedy.

1. Overall Protection of Human Health and the EnvironmentOverall protection of human health and the environment determines whether an alternative eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or treatment.

Alternative 1 does not protect human health and the environment because no action is taken to prevent exposure to sediment/soil that exceeds risk based cleanup goals for arsenic.

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Alternative 2 is protective of human health and the environment because sediment/soil is removed as it reaches arsenic concentrations that exceed the risk based cleanup goals.

Alternative 3 is protective of human health and the environment because in-situ treatment systems are installed and operated that prevent recontamination of sediment/soil with arsenic, and sediment/soil currently exceeding risk based arsenic concentrations are removed and disposed of off-site.

2. Compliance with applicable or relevant and appropriate requirements (ARARs)Section 121 (d) of CERCLA, 42 U.S.C. § 9621(d), and Section 300.430(f)(1)(ii)(B) of the NCP, 40 CFR §300.430(f)(1)(ii)(B), require that remedial actions at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State requirements, standards, criteria and limitations which are collectively referred to as “ARARs,” unless such ARARs are waived under Section 121(d)(4) of CERCLA.

Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and State environmental statutes or provides a basis for invoking a waiver.

A complete list of ARARs can be found in Appendix II, Table 7.

Alternative 1 would not comply with ARARs in that it would leave exposed sediment/soil in place that exceed New Jersey RDCSRS and pose unacceptable risk to human health and the environment.

Alternative 2 provides compliance with chemical-specific ARARs by removal of sediment/soil that exceeds New Jersey RDCSRS. Location-specific ARARs and Action-specific ARARs would both be met by proper design and implementation of the respective components such as general construction standards and waste handling requirements. The Location-specific ARARs and Action-specific ARARs for the disposal phase would be met with proper waste management on-site, and selection of the disposal facility.

Alternative 3 provides compliance with chemical-specific ARARs by removing contaminated soil above New Jersey RDCSRS and in-situ treatment that would prevent groundwater from recontaminating the sediment/soil. Location-specific ARARs and Action-specific ARARs would both be met by proper design and implementation of the respective components such as general construction standards and waste handling requirements. The Location-specific ARARs and Action-specific ARARs for the disposal phase would be met with proper waste management on-site, and selection of the disposal facility.

Primary Balancing Criteria – The next five criteria, criteria 3 through 7, are known as “primary balancing criteria”. These criteria are factors by which tradeoffs between response measures are assessed so that the best options will be chosen, given site-specific data and conditions.

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3. Long-Term Effectiveness and PermanenceLong-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the environment over time.

Although the three alternatives are interim remedial actions, they were evaluated for long-term effectiveness and permanence. This interim remedy is intended to be protective of human health and the environment until EPA decides on a permanent remedy for this OU.

Alternative 1 does not provide adequate controls of risks to human health over the long-term because there is no mechanism to prevent future exposure.

Alternative 2 is only effective in the long-term with a high level of constant maintenance. It does not treat the source of contamination, and although steps would be taken to protect the surrounding community, there would be nearly continuous operation of construction equipment and hauling of contaminated soil off-site for an indefinite period of time.

Alternative 3 is effective in the long-term in that it prevents recontamination of the exposed sediment/soil in the Blackwater Branch floodplain.

4. Reduction of Toxicity, Mobility, or Volume through TreatmentReduction in Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment and the amount of contamination present.

Alternative 1 would not reduce the toxicity, mobility or volume of contaminated soil, since the soil would remain in place.

Alternative 2 would not provide reduction of toxicity, mobility, or volume of contamination through treatment.

Alternative 3 does not reduce the overall volume of arsenic but does reduce the mobility of arsenic in the groundwater, which reduces the volume entering the Blackwater Branch floodplain. This effectively reduces the toxicity of the groundwater entering the Blackwater Branch floodplain.

5. Short-Term EffectivenessShort-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to workers, residents and the environment during implementation.

Alternative 1 poses no short-term adverse impacts to the community.

Alternative 2 construction and implementation activities would be frequent and would have almost continuous impact on the local community with truck traffic to haul contaminated sediment/soil for off-site disposal.

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Alternative 3 would have some impacts on the nearby community due to truck traffic to haul contaminated sediment/soil off-site and drilling activities to install the in-situ treatment systems. However, these impacts would be relatively short term and ongoing long term treatment activities at the site are expected to have minimal impact to the community. Both alternatives would result in some short-term impacts to the community, in the form of vehicular (truck) traffic and noise and dust from construction/excavation activities, although Alternative 2 would generate less truck traffic than Alternative 3. Traffic, noise, and dust impacts could be mitigated to some extent by limiting the construction schedule to daytime hours on weekdays or other timing as specified by local ordinance. Perimeter air monitoring and dust control measures would be required to address concerns over exposure to dust during activities. 6. Implementability Implementability addresses the technical and administrative feasibility of a remedy from design through construction and operation. Factors such as availability of services and materials, administrative feasibility, and coordination with other governmental entities are also considered. Alternative 1 requires no implementation. Alternative 2 can be easily implemented. There are no special techniques, materials, or labor required to implement Alternative 2. Alternative 3 is administratively and technically feasible; however, implementation of Alternative 3 would take a greater level of effort than Alternative 2 because it requires the design of an in-situ treatment component. 7. Cost Cost includes estimated capital and annual operation and maintenance costs, as well as present worth cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are expected to be accurate within a range of +50 to -30 percent (This is a standard assumption in accordance with EPA guidance).

The estimated capital cost, operation and maintenance (O&M), and present worth costs are discussed in detail in EPA’s FFS. The cost estimates are based on the best available information. Alternative 1 has no cost because no activities are implemented. The estimated capital, O&M present-worth cost over a ten year period, and total present-worth costs for each of the alternatives are as follows:

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Cost Summary Capital Cost

Annual O&M

Performance Monitoring

10-year Present Worth

Alternative 1: No Further Action $0 $0 - $0 Alternative 2: - Ongoing Hot Spot Excavation 1 $1,160,646 $4,642,584 - $33,768,213Alternative 3: In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring 2 $9,988,488 $745,569 $213,438 $14,897,663

Alternative 3: Year 2 - $557,670 $135,461 - Alternative 3: Years 3-10 - $557,670 $95,663 -

1 $1,160,646 is for one time excavation of all areas. $4,642,584 annual cost is excavation every 3 months. 2 Capital Cost includes installation of in-situ remedies in Areas A, B, and C and one time excavation of hotspots.

Modifying Criteria – The final two evaluation criteria, criteria 8 and 9, are called “modifying criteria” because new information or comments from the state or the community on the Proposed Plan may modify the preferred response measure or cause another response measure to be considered.

8. State AcceptanceState Agency acceptance considers whether the State and/or Support Agency agrees with EPA’s analyses and recommendations.

The State of New Jersey concurs with the selected remedy. A letter of concurrence is attached in Appendix IV.

9. Community AcceptanceCommunity Acceptance considers whether the local community agrees with EPA's analyses and preferred alternative. Comments received on the Proposed Plan are an important indicator of community acceptance.

On August 8, 2016, EPA held a formal public meeting on the proposed plan for this OU. All written and oral comments are addressed in detail in Appendix V, which is the Responsiveness Summary for this ROD Amendment. No comments received during the comment period for the proposed plan expressed disagreement with EPA’s preferred alternative for this OU at the site.

7.0 SELECTED AMENDED REMEDY

Based upon the requirements of CERCLA, the results of the site investigations, the detailed analysis of the alternatives, and public comments, EPA has determined that Alternative 3 (In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring) satisfies the requirements of Section 121 of CERCLA, 42 U.S.C. § 9621, and provides the best balance of tradeoffs among

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the remedial alternatives with respect to the NCP’s nine evaluation criteria, 40 C.F.R. § 300.430(e)(9).

The major components of this ROD Amendment for OU3 include:

Installation of in-situ treatment technologies to prevent recontamination of theexposed sediment/soil to concentrations above Remediation Goals.

Excavation of localized areas of sediment/soil in the Blackwater Branchfloodplain with concentrations of contaminants above Remediation Goals.

Performance monitoring to assure the remedy is effective and assess the need foradditional in-situ treatment and/or excavation.

This alternative consists of installation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil to concentrations above remediation goals, excavation of localized areas of sediment/soil in the Blackwater Branch floodplain with concentrations of contaminants above remediation goals, and performance monitoring to assure the remedy is effective and assess the need for additional in-situ treatment and/or excavation.

The in-situ technology that will be used depends on the geochemistry and subsurface conditions in each particular location. The actual technology will be selected during the Remedial Design. For the purposes of cost estimation the following were used as representative technologies: air sparging in iron rich groundwater environments; iron chloride injection in addition to air sparging in iron poor groundwater environments; sodium bicarbonate or sodium hydroxide injections for pH adjustments. As noted above, the final selection of the in-situ treatment technology appropriate for each area of the site will be made after further studies during remedial design.

This is considered an interim remedial action that will be revisited at a future date once the long-term effectiveness as a part of the remedy for all operable units of the site is evaluated. Additional ROD Amendments, for this OU or others, may be warranted in the future. This selected interim remedy will ensure that recontaminated sediment/soil will be remediated to levels that are protective of human and ecological health.

8.0 STATUTORY DETERMINATIONS

CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions be protective of human health and the environment, be cost-effective, and use permanent solutions, alternative treatment technologies, and resource recovery alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a preference for remedial actions which employ, as a principal element, treatment to reduce the volume, toxicity, or mobility of the hazardous substances, pollutants, and contaminants at a site permanently and significantly. CERCLA Section 121(d), 42 U.S.C. § 9621(d), further specifies that a remedial action must attain a level or standard of control of the hazardous substances, pollutants and contaminants, which at least attains ARARs under federal and state laws, unless a waiver can be justified.

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EPA has determined that the selected remedy complies with the CERCLA and NCP provisions for remedy selection, meets the threshold criteria, and provides the best balance of tradeoffs among the alternatives with respect to the balancing and modifying criteria. These provisions require the selection of remedies that are protective of human health and the environment, comply with ARARs (or justify a waiver from such requirements), are cost-effective, and utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. In addition, CERCLA includes a preference for remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous substances as a principal element (or justify not satisfying the preference). The following sections discuss how the selected remedy meets these statutory requirements. The State of New Jersey concurs with the selected remedy.

8.1 Protection of Human Health and the Environment

The selected remedy, Alternative 3, will adequately protect human health and the environment through a combination of excavation, in-situ treatment, and performance monitoring. The selected remedy will eliminate all significant direct-contact risks to human health and the environment associated with contaminated exposed sediment/soil of the Blackwater Branch and its floodplain. This action will result in the reduction of exposure levels to acceptable risk levels within EPA’s generally acceptable risk range of 10-4 to 10-6 for carcinogens and below a HI of 1.0 for noncarcinogens. Implementation of the selected remedy will not pose unacceptable short-term risks.

8.2 Compliance with ARARs

The selected remedy complies with Chemical-specific, Location-specific and Action-specific ARARs. The ARARs for the selected interim OU3 remedy include the chemical-specific New Jersey Residential Direct Contact Soil Remediation Standards (NJAC 7:26D), the location-specific New Jersey Flood Hazard Control Act (NJAC 7:13) and the action-specific Resource Conservation and Recovery Act (42 USC 6901 et seq.; 40 CFR 107, 171-177). A complete list of the ARARs, TBCs and other guidance that concern the selected remedy is presented in Appendix II, Table 7.

8.3 Cost-Effectiveness

EPA has determined that the selected remedy is cost-effective and represents reasonable value for the money to be spent. A cost-effective remedy is one whose costs are proportional to its overall effectiveness (NCP § 300.4309f)(1)(ii)(D)). EPA evaluated the “overall effectiveness” of those alternatives that satisfied the threshold criteria (i.e. were both protective of human health and ARAR-compliant). Overall effectiveness is based on the evaluations of long-term effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment; and short-term effectiveness. Overall effectiveness was then compared to costs to determine cost-effectiveness.

Each of the alternatives were subjected to a detailed cost analysis. In that analysis, capital, annual O&M, and performance monitoring costs were estimated and used to develop present-worth

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costs. The estimated present worth cost of the selected soil remedy for OU3 is $14,897,663, which is less expensive than Alternative 2. The selected remedy is cost-effective as it has been determined to provide the greatest overall protectiveness for its present-worth cost. 8.4 Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery) Technologies to Maximum Extent Practicable EPA has determined that the amended remedy represents the maximum extent to which permanent solutions and treatment technologies can be utilized in a practicable manner for this OU. Of those alternatives that are protective of human health and the environment and comply with ARARs (or provide a basis for invoking an ARAR waiver), EPA has determined that the selected remedy provides the best balance of trade-offs in terms of the five balancing criteria, while also considering the statutory preference for treatment as a principal element, the bias against off-site disposal without treatment, and State/support agency and community acceptance. 8.5 Preference for Treatment as a Principal Element By utilizing in-situ methods to prevent recontamination of the sediment/soil, the amended remedy addresses contamination posed by the site through the use of treatment technologies. By utilizing treatment as a significant portion of the remedy the statutory preference for remedies that employ treatment as a principal element is satisfied. 8.6 Five-Year Review Requirements While this amended remedy will ultimately result in reduction of contaminant levels in sediment/soil to levels that would allow for unlimited use and unrestricted exposure, it will take longer than five years to achieve these levels. As a result, the site will be reviewed at least once every five years until such time as RAOs and remediation goals are attained and human health and the environment are protected with unrestricted use. 9.0 DOCUMENTATION OF SIGNIFICANT CHANGES The Proposed Plan for OU3 of the Vineland Chemical Company site was released for a public comment period on July 22, 2016. The public comment period ran until August 22, 2016. The Proposed Plan identified Alternative 3 (In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring) as the preferred alternative for OU3 of the site. EPA reviewed all written (including electronic formats such as e-mail) and verbal comments submitted during the public comment period and has determined that no significant changes to the remedy, as it was originally identified in the Proposed Plan, are necessary or appropriate.

APPENDIX I

Figures

Vineland Chemical Company

Superfund Site

Figure 1: Site Location

Vineland Chemical Company Superfund Site

Figure 2: Site Overview


Superfund Site

Figure 3: Operable Units


Superfund Site

Figure 4: Delineation of Areas A, B, and C

APPENDIX II

Tables

TABLE 1 Summary of Chemicals of Concern and

Medium-Specific Exposure Point Concentrations

Scenario Timeframe: Future Medium: Sediment Exposure Medium: Exposed Sediment

Exposure Point Chemical of Concern

Concentration Detected Concentration

Units Frequency

of Detection

Exposure Point Concentration

(EPC)

EPC Units

Statistical Measure

Min Max

Blackwater Branch Area C

Arsenic 1 1,470 mg/kg 100% 1,470 mg/kg Maximum

Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations

This table presents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for the COCs in exposed sediment. The table includes the range of concentrations detected for each COC, as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples collected at the site), the

EPC and how it was derived.

TABLE 2 Selection of Exposure Scenarios

Scenario Timeframe

Medium Exposure Medium Exposure Point Receptor

Population Receptor Age Exposure Route Type of Analysis

Future Sediment Exposed Sediment Blackwater Branch

Area C Recreator

Adult and Child (birth to <6 years)

Ing/Der/Inh Quantitative

Ing – Ingestion

Der – Dermal

Inh - Inhalation

Summary of Selection of Exposure Pathways This table describes the exposure pathways that were evaluated for the risk assessment. Exposure media, exposure points, and characteristics of receptor populations are

included.

TABLE 3 Non-Cancer Toxicity Data Summary

Pathway: Oral/Dermal

Chemical of Concern

Chronic/ Subchronic

Oral RfD

Value

Oral RfD Units

Absorp. Efficiency (Dermal)

Adjusted RfD

( Dermal)

Adj. Dermal

RfD Units

Primary Target Organ

Combined Uncertainty /Modifying

Factors

Sources of RfD: Target Organ

Dates of RfD:

Arsenic Chronic 3.0E-04 mg/kg-day 95% 3.0E-04 mg/kg-day Skin 3 IRIS 9/1/1991

Key

IRIS: Integrated Risk Information System

Summary of Toxicity Assessment

This table provides non-carcinogenic risk information which is relevant to the contaminants of concern. When available, the chronic toxicity data have been used to develop oral reference doses (RfDs).

TABLE 4 Cancer Toxicity Data Summary

Pathway: Oral/Dermal

Chemical of Concern Oral Cancer Slope Factor

Units Adjusted Cancer Slope

Factor (for Dermal)

Slope Factor Units

Weight of Evidence/

Cancer Guideline

Description

Source Date

Arsenic 1.5E+00 mg/kg-day 1.5E+00 mg/kg-day A IRIS 06/01/95

Key:

A: Known Human Carcinogen IRIS: Integrated Risk Information System

Summary of Toxicity Assessment

This table provides carcinogenic risk information which is relevant to the contaminants of concern. Toxicity data are provided for both the oral and dermal routes of exposure.

TABLE 5

Risk Characterization Summary - NoncarcinogensScenario Timeframe: Future Receptor Population: Recreator Receptor Age: Adult

Medium Exposure Medium

Exposure Point Chemical of Concern Primary

Target Organ

Non-Carcinogenic Risk

Ingestion Dermal Inhalation Exposure

Routes Total

Sediment Exposed Sediment


Arsenic Skin 4.0E-01 8.5E-02 5.5E-04 4.9E-01

Scenario Timeframe: Future Receptor Population: Recreator Receptor Age: Child


Exposure Point Chemical of Concern Primary

Target Organ

Non-Carcinogenic Risk

Ingestion Dermal Inhalation Exposure

Routes Total



Arsenic Skin 4.0E+00 5.1E-01 5.5E-04 4.8E+00

Summary of Risk Characterization - Non-Carcinogens

The table presents hazard quotients (HQs) for each route of exposure and the hazard index (sum of hazard quotients) for exposure to groundwater containing site-related chemicals. The Risk Assessment Guidance for Superfund states that, generally, a hazard index (HI) greater than 1 indicates the potential for adverse

non-cancer effects.

TABLE 6

Risk Characterization Summary - Carcinogens

Scenario Timeframe: Future Receptor Population: Recreator Receptor Age: Lifetime (Adult/child)


Exposure Point Chemical of Concern

Carcinogenic Risk

Ingestion Dermal Inhalation Exposure Routes Total



Arsenic 2.2E-04 3.1E-05 1.3E-08 2.5E-04

Summary of Risk Characterization – Carcinogens

The table presents site-related cancer risks for groundwater exposure. As stated in the National Contingency Plan, the point of departure is 10-6 and the acceptable risk range for site-related exposure is 10-6 to 10-4. The cancer risk from arsenic in surface soil exceeds the acceptable risk range, indicating an unacceptable risk from residential exposure to soil.

TABLE 7 ARARs and To Be Considered (TBC) Criteria

CHEMICAL-SPECIFIC ARARS OR TBC CRITERIA REGULATOR CRITERION CITATION DESCRIPTION COMMENTS

NJ Statutes and Rules

Remediation Standards Rule

NJAC 7:26D

Establishes minimum remediation standards for direct contact exposure to soil.

The Residential Direct Contact Soil Remediation Standard for Arsenic is 19 mg/kg

Federal Acts and Regulations

OSWER Guidance for Developing Ecological Soil Screening Levels

OSWER 9285.7.55

Guidance for deriving risk based eco-SSLs for soil contaminants of ecological concern.

May be used to screen soil contaminants to determine if further ecological study is warranted.


OSWER Soil Screening Guidance

OSWER 9285.7.55

Guidance for developing site specific soil screening levels.

May be used to identify areas of soil contamination.

LOCATION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR CRITERION CITATION DESCRIPTION COMMENTS NJ Statutes and Rules

Flood Hazard Control Act NJAC 7:13 Floodplain Use and Limitations which establishes limits on land development within flood hazard areas

Pertinent to activities that may occur within the floodplain.


Freshwater Wetlands Protection Act

NJSA 13:9B-1 et seq

Requires permits for regulated activity disturbing freshwater wetlands

Potentially applicable for construction activities performed in the vicinity of a freshwater wetland


Endangered Plant Species List Act

NJSA 13:1B et seq.

Establishes the requirement to protection threatened and endangered plant species in New Jersey by developing and adopting a list


Endangered and Non-Game Species Conservation Act

NJSA 23:2A-1

Standards for the protection of Federal and NJ threatened and endangered species


Stream Encroachment Permit

N.J.S.A. 58:16A-50 et seq.; N.J.A.C. 7:8-3.15

Construction of structures and placement of fill within flood hazard areas including floodplains and floodways

Potentially applicable for construction activities performed in floodplains and floodways (e.g., treatment facilities)


National Environmental Policy Act (NEPA)

40 CFR 6, Appendix A

Statement of Procedures on Floodplain Management and Wetlands Protection. Establishes policy and guidance to avoid the occupancy and modification of floodplains, or the destruction or modification of wetlands


Endangered Species Act

40 CFR 400 50 CFR 17, 81, 223, 224, 226, 402

Standards for the protection of threatened and endangered species (wildlife, marine and anadromous species and plants) and establish cooperation with the Federal and State Governments

LOCATION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR CRITERION CITATION DESCRIPTION COMMENTS Federal Acts and Regulations

Fish and Wildlife Conservation Act

16 USC 2901 et seq.

Established EPA policy and guidance for promoting the conservation of non-game fish and wildlife and their habitats

Potentially applicable for construction activities performed which may impact non- game fish and wildlife and their habitats


Protection of Migratory Game & Insectivorous Birds

16 USC 703 Preservation of migratory birds and habitat Potentially applicable for any area with nesting migratory birds


National Historic Preservation Act

16 USC 469 et seq.; 40 CFR 6301

Establishes procedures to provide for preservation of historical and archaeological data that might be destroyed through alteration of terrain as a result of a Federally licensed activity or program

ACTION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR CRITERION CITATION DESCRIPTION COMMENTS NJ Statutes and Rules

Well Construction and Maintenance

NJAC 7:9D Establishes requirements for construction and decommission (sealing) of wells, and well driller / pump installer licensing

Applicable if wells are constructed or decommissioned


New Jersey Soil Erosion and Sediment Control Act

NJSA 4:24-39 et seq

To establish soil erosion and sediment control standards for Department of Transportation certification of its projects to the Soil Conservation Districts


New Jersey Air Pollution Control Act

NJAC 7:27-8, 16

Establishes standards for discharge of pollutants to air


Pollutant Discharge Elimination System

NJAC 7:14A

Establishes standards for discharge of pollutants to surface and ground waters

Potentially applicable if wastewater is discharged to surface or ground water


Technical Requirements for Site Remediation (TRSR) and Administrative Requirements for the Remediation of Contaminated Sites (ARRCS)

NJAC 7:26E- 8

Identifies requirements for institutional controls for contaminated soils left in place, and for contaminated groundwater; identifies administrative requirements for site remediation that may be applicable

Potentially applicable if chemical residuals in soils left in place are above the industrial SRS; potentially applicable to CEA and MNA implementation


Noise Control NJAC 7:29 Establishes allowable noise levels Potentially applicable in residential areas


SDWA 40 CFR 144- 147

Underground injection control regulations that provide for the protection of underground sources of drinking water


Clean Water Act (CWA) 33 USC 1251 et seq.

Procedures to preserve surface water quality by reducing direct pollutant discharges into waterways, finance municipal wastewater treatment facilities and manage polluted runoff


REGULATOR CRITERION CITATION DESCRIPTION COMMENTS


National Pollution Discharge Elimination System (NPDES)

40 CFR 122- 125

Establishes requirements for discharges associated with industrial activity, to water bodies or wetlands

Water quality standards and best management practices apply, and a discharge permit is required


Ambient Water Quality Criteria (AWQC)

40CFR131, 401

Provides criteria developed for the protection of freshwater and marine aquatic life and for the protection of human health from the ingestion of water and/or organisms

General Pretreatment Regulations for Existing and New Sources of Pollution

40 CFR 403 Prohibits discharge of pollutants to a Publically Operated Treatment Works (POTW) which cause or may cause pass-through or interference with operation of the POTW

Potentially applicable if water is discharged to a POTW


Fish and Wildlife Coordination Act

16 USC 661- 666

Requires consultation when a federal department or agency proposes or authorizes any modification of any stream or other water body and adequate provision for protection of fish and wildlife resources


Toxic Pollutant Effluent Standards

40 CFR 129 Establishes effluent standards or prohibitions for certain toxic pollutants such as pesticides and PCBs


RCRA 42 USC 6901 et seq.; 40 CFR 260-270

Establishes responsibilities and standards for the management of hazardous and non-hazardous waste

Applicable to solid waste streams from drill cuttings during well installation


Hazardous Materials Transportation Act (HMTA)

49 USC 1801- 1813; 49 CFR 107, 171-177

Regulates transportation of hazardous materials in commerce

Potentially applicable for transportation of drill cuttings


Clean Air Act (CAA) 42 USC 7401 Establishes requirements to preserve air quality and to reduce air pollution


National Ambient Air Quality Standards (NAAQs)

40 CFR 50 Establishes primary and secondary standards for six pollutants to protect the public health and welfare


REGULATOR CRITERION CITATION DESCRIPTION COMMENTS


National Emission Standards for Hazardous Air Pollutants (NESHAPs)

40 CFR 63 Establishes regulations for specific air pollutants (such as benzene and PCE)

Notes: ARAR Applicable or relevant and appropriate requirement ARRCS Administrative Requirements for the Remediation of Contaminated Sites AWQC Ambient Water Quality Criteria CFR Code of Federal Regulations CAA Clean Air Act CEA Classification Exception Area CWA Clean Water Act EPA U.S. Environmental Protection Agency HMTA Hazardous Materials Transportation Act mg/kg Milligrams per kilogram MNA Monitored Natural Attenuation NAAQ National Ambient Air Quality Standards NEPA National Environmental Policy Act NESHAP National Emission Standards for Hazardous Air Pollutants NJ New Jersey NJAC New Jersey Administrative Code, Chapters as specified NJSA New Jersey Statutes NPDES National Pollutant Discharge Elimination System OSWER Office of Solid Waste and Emergency Response PCB polychlorinated biphenyl PCE perchloroethylene POTW Publicly Operated Treatment Works RCRA Resource Conservation and Recovery Act SDWA Safe Drinking Water Act SSL Soil Screening Levels TBC To Be Considereds TRSR Technical Requirements for Site Remediation USC United States Code Also note: While not an ARAR, all relevant sections of the Occupational Safety and Health Standards and Safety and Health Regulations for Construction (29 CFR 1910 and 1926) will be complied with.

APPENDIX III

Administrative Record Index

Page 1 of 1

FINAL07/21/2016 REGION ID: 02

Site Name: VINELAND CHEMICAL CO., INC.CERCLIS ID: NJD002385664

OUID: 03SSID: 02B8

Action: Blackwater Branch

DocID: Doc Date: Title:Image Count: Doc Type: Addressee Name/Organization: Author Name/Organization:

395954 7/21/2016 ADMINISTRATIVE RECORD INDEX FOR OU3 FOR THE VINELAND CHEMICAL COMPANY INCORPORATED SITE

1 ARI / Administrative Record Index

R02: (US ENVIRONMENTAL PROTECTION AGENCY)

99365 9/28/1989 RECORD OF DECISION FOR THE VINELAND CHEMICAL COMPANY INCORPORATED SITE

225 RPT / Report R02: (US ENVIRONMENTAL PROTECTION AGENCY)

395912 7/19/2016 FOCUSED FEASIBILITY STUDY FOR OU3 FOR THE VINELAND CHEMICAL COMPANY INCORPORATED SITE

110 RPT / Report

396032 7/20/2016 FOCUSED FEASIBILITY STUDY ADDENDUM FOR OU3 FOR THE VINELAND CHEMICAL COMPANY INCORPORATED SITE

4 MEMO / Memorandum

R02: Young, Hunter (US ENVIRONMENTAL PROTECTION AGENCY)

395948 7/21/2016 PROPOSED PLAN FOR OU3 FOR THE VINELAND CHEMICAL COMPANY INCORPORATED SITE

14 WP / Work Plan R02: (US ENVIRONMENTAL PROTECTION AGENCY)

ADMINISTRATIVE RECORD INDEX OF DOCUMENTS

https://semspub.epa.gov/src/document/02/395954





APPENDIX IV

State Letter

CHRIS CHRISTIE Governor

KIM GUADAGNO Lt. Governor

Mr. Walter Mugdan, Director

~hde of ~ efu Wen~eJJ D EPARTMENT OF ENVIRONMENTAL P ROTECTION

S ITE REMEDIATION PROGRAM

Mail Code 40 l -06 P. 0. Box 420

Trenton, New Jersey 08625-0420 Tel. #: 609-292- 1250 Fax.#: 609-777-1914

Emergency and Remedial Response Division U.S. Environmental Protection Agency Region II 290 Broadway New York, NY 10007-1866

Re: Vineland Chemical Company Superfund Site Record of Decision Amendment Operable Unit 3 EPA ID# NJD002385664 DEP PI# 0011 40

Dear Mr. Mugdan:

BOB MARTIN Commissioner

September 22, 2016

The New Jersey Department of Environmental Protection (DEP) completed its review of the "Record of Decision Amendment, Vineland Chemical Company Superfund Site, Cumberland County, New Jersey, Operable Unit 3: Exposed Sediment of the Blackwater Branch" prepared by the U.S. Environmental Protection Agency (EPA) Region II in August 2016 and concurs with the selected remedy to address arsenic contamination to protect local waterways.

The new remedial actions included in this Record of Decision Amendment cover a discrete portion of OU 3 of the site involving exposed sediment/soil of the Blackwater Branch floodplain near the former Vineland Chemical Company property. The selected remedy, with an estimated present-worth cost of $14,897 ,663, is considered an interim remedial action that will be revisited at a future date once its long-term effectiveness as a part of the remedy for all operable units of the site is evaluated.

During di scussions between EPA and DEP about this ROD amendment, it was noted that further evaluation of the site's current groundwater treatment system in Operations and Maintenance with state contractors should be included for review during these new remedial actions on site. The groundwater remedy began operation in spring 2000 and transitioned to state control in October 2014.

Ne111 Jersey is an £q11al Opportunity Employer 1 Pr in Jed on Raycled Paper and Recyclable

The major components of this ROD Amendment to address certain areas of exposed sediment/soil of the Blackwater Branch floodplain that have become re-contaminated with arsenic above the cleanup goals identified in the 1989 ROD due to arsenic in grow1dwater impacting these sediment/soil areas include the following:

• Installation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil to concentrations above remediation goals.

• Hot-spot excavations to remove exposed sediment/soil in the Blackwater Branch floodplain above remediation goals.

• Performance monitoring and assessment of the need for additional in-situ treatment and/or excavation.

The in-situ technology used may vary across the site and will depend on the geochemistry and subsurface conditions in each particular location. Examples of such technologies include air sparging in iron rich groundwater environments and iron chloride injection in addition to air sparging or peroxide injection in iron poor groundwater enviro1m1ents. In-situ teclmologies may also include pH adjustments and/or the installation reactive barriers. In addition, the need for excavation of the exposed sediment/soil before and/or after in-situ treatment for each area of the site will be determined during the remedial design and refined during the remedial action.

DEP appreciates the opportunity to participate in the decision making process to select an appropriate remedy for this site. Further, DEP is looking forward to future cooperation with EPA in remedial actions to ensure a full cleanup at all areas impacted by this site.

If you have any questions, please call me at 609-292-1251.

0

Director, 1sion of Remediation Management Site Remediation & Waste Management Program

C: Mark J. Pedersen, Assistant Commissioner, Site Remediation & Waste Management Program

Edward W. Putnam, Assistant Director, Publicly funded Response Element, DEP Carole Petersen, Chief, New Jersey Remediation Branch, EPA Region II

APPENDIX V

Responsiveness Summary

1

RESPONSIVENESS SUMMARY

FOR THE

RECORD OF DECISION AMENDMENT

VINELAND CHEMICAL COMPANY SITE

CUMBERLAND COUNTY, NEW JERSEY

INTRODUCTION

This Responsiveness Summary provides a summary of comments and concerns provided during the public comment period related to the Proposed Plan (Attachment A) for Operable Unit 3 (OU3) of the Vineland Chemical Company Superfund site (the site) and provides the U.S. Environmental Protection Agency’s (EPA’s) responses to those comments. All comments summarized in this document have been considered in EPA’s final decision in the selection of a remedy to address the contamination at the site. SUMMARY OF COMMUNITY RELATIONS ACTIVITIES All documentation which the EPA used to develop the Proposed Plan and select the remedy in this Record of Decision (“ROD”) Amendment, including the EPA’s Focused Feasibility Study dated July 2016, are in the Administrative Record for the site which was made available to the public beginning July 22, 2016 in the information repositories maintained in the EPA Docket Room at the EPA Region 2 offices at 290 Broadway, New York, New York, at the Vineland Public Library, 1058 East Landis Avenue, Vineland, New Jersey and on EPA’s website for the site, www.epa.gov/superfund/vineland-chemical. On July 22, 2016, EPA published a notice in the Press of Atlantic City newspaper informing the public of the commencement of the public comment period for the Proposed Plan, the upcoming public meeting on August 8, 2016, the preferred remedy for OU3, contact information for EPA personnel, and the availability of site-related documents in the Administrative Record. Copies of the notice can be found in Attachment B of this appendix. The Proposed Plan is available at each of the repositories listed above, including online. The public comment period ran from July 22, 2016 to August 22, 2016. EPA held a public meeting on August 2, 2016 at 6:30 P.M. in the City Council Chambers of Vineland City Hall at 640 E Wood Street, Vineland, New Jersey, to present the findings of the Proposed Plan, and to answer questions from the public about the Proposed Plan, the remedial alternatives evaluated, and EPA’s preferred alternative.

2

SUMMARY OF COMMENTS AND RESPONSES A summary of the comments provided at the public meeting and all written comments submitted during the public comment period, as well as the EPA’s responses to them, are provided below. The transcript from the public meeting and the comments submitted during the public comment period can be found in Attachments C and D, respectively, of this appendix.

Comment 1: The City of Vineland Health Department endorses EPA’s preferred alternative. EPA Response to Comment 1: EPA acknowledges the comments in support of its preferred alternative. ATTACHED TO THIS RESPONSIVENESS SUMMARY ARE THE FOLLOWING: Attachment A - Proposed Plan Attachment B - Public Notice - Press of Atlantic City Attachment C - August 8, 2016 Public Meeting Transcript Attachment D - Comments Submitted During Public Comment Period

Attachment A

Proposed Plan

EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan describes the remedial alternatives that the United States Environmental Protection Agency (EPA) considered for amending the approach to remediate contaminated exposed sediment/soil of the Blackwater Branch floodplain that are associated with the Vineland Chemical Company Superfund site located in Vineland, New Jersey. This Plan also identifies EPA’s Preferred Alternative along with the reasons for this preference.

This Proposed Plan includes summaries of cleanup alternatives evaluated for use at the affected floodplain areas. This Proposed Plan was developed by EPA, the lead agency for the site, in consultation with the New Jersey Department of Environmental Protection (NJDEP), the support agency. As described herein, there are larger issues related to groundwater contamination at the site that are still being evaluated. As such, this Proposed Plan describes interim alternatives for the Blackwater Branch floodplain that may be revisited at a future date. EPA, in consultation with NJDEP, will select an interim remedial action that amends the current remedy for exposed sediment/soil of the Blackwater Branch floodplain after reviewing and considering all information submitted during the 30-day public comment period. EPA, in consultation with NJDEP, may modify the Preferred Alternative or select another response action presented in this Plan based on new information or public comments. Therefore, the public is encouraged to review and comment on the alternatives presented in this Proposed Plan.

EPA is issuing this Proposed Plan in accordance with Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund) 42 U.S.C. 9617(a), and Section 300.435(c) (2) (ii) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This Proposed Plan summarizes information that can be found in greater detail in the Focused Feasibility Study

(FFS) and other related documents contained in the publicly available Administrative Record for the site. EPA encourages the public to review these documents to gain a more comprehensive understanding of the site and Superfund activities that have been conducted. The current remedy for this portion of the site, selected in a 1989 Record of Decision (ROD), consists of dredging, excavation, and disposal of contaminated sediment and soil in the Blackwater Branch floodplain. The Preferred Alternative identified in this Proposed

Vineland Chemical Company Superfund Site Blackwater Branch Exposed Sediment/Soil

Vineland, New Jersey

Superfund Proposed Plan July 2016

MARK YOUR CALENDARS

Public Comment Period July 22 –August 22, 2016

EPA will accept written comments on the Proposed Plan during the public comment period. Written comments should be addressed to:

Hunter Young Remedial Project Manager U.S. Environmental Protection Agency 290 Broadway, 18th Floor New York, NY 10007 Email: [email protected]

Written comments must be postmarked no later than August 22, 2016.

Public Meeting August 8, 2016 at 6:30 P.M.

EPA will hold a public meeting to explain the Proposed Plan and all of the alternatives presented in the Feasibility Study. Oral and written comments will also be accepted at the meeting. The meeting will be held at:

Vineland City Hall – City Council Chambers 640 E Wood St, Vineland, NJ 08360

In addition, select documents from the administrative record are available on-line at:

www.epa.gov/superfund/vineland-chemical

2

Plan would amend that ROD to require implementation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil (which is generally defined as sediment located above the average high water line), excavation of localized areas of sediment/soil in the Blackwater Branch floodplain with significantly elevated concentrations of contaminants, and performance monitoring to assure the remedy is effective and to assess the need for additional in-situ treatment and/or excavation. COMMUNITY ROLE IN SELECTION PROCESS

This Proposed Plan is being issued to inform the public of EPA’s proposed alternative and to solicit public comments pertaining to all of the remedial alternatives evaluated, including the Preferred Alternative. Changes to the Preferred Alternative, or a change to another alternative, may be made if public comments or additional data indicate that such a change would result in a more appropriate remedial action. The final decision regarding the selected remedy will be made after EPA has taken into consideration all public comments. EPA is soliciting public comments on all of the alternatives considered in the Proposed Plan, because EPA may select a remedy other than the Preferred Alternative. This Proposed Plan has been made available to the public for a public comment period that concludes on August 20, 2016. A public meeting will be held during the public comment period to present the information regarding the investigations of the Blackwater Branch floodplain, including the conclusions of studies performed to assess treatment options and the FFS, to elaborate further on the reasons for proposing the Preferred Alternative, and to receive public comments. The public meeting will include a presentation by EPA of the Preferred Alternative and other cleanup options. Information on the public meeting and submitting written comments can be found in the “Mark Your Calendar” text box on Page 1. Comments received at the public meeting, as well as written comments received during the comment period, will be documented in the Responsiveness Summary section of the ROD Amendment. The ROD Amendment is the document that presents which alternative has been selected and the basis for the selection of the remedy.

SCOPE AND ROLE OF RESPONSE ACTION

The site is divided into four operable units (Figure 2). The 1989 ROD selected remedies to address each of the operable units, and several parts of the cleanup work specified in the ROD have already been completed. Operable Unit 1 (OU1) consisted of the control of source material at the former Vineland Chemical Company plant site. To address arsenic-contaminated soil, EPA constructed a soil washing facility that processed 70 tons of excavated soil per hour. The facility processed over 400,000 tons of arsenic-contaminated soil and sediment, and the remaining waste was disposed of at a permitted off-site disposal facility. The soil remedy was completed in 2014. OU2 relates to management of the migration of contamination through groundwater. To address contaminated groundwater, EPA constructed a system to pump out and treat about two million gallons of contaminated groundwater daily. Operation of the facility began in the spring of 2000 and is ongoing. The pump-and-treat operation is capturing the majority of the flow of arsenic-contaminated groundwater from the plant site. The treated groundwater continues to meet the site’s cleanup goal. Operation of the pump-and-treat system was transferred to NJDEP in October 2014. The primary objective of the response action described herein involves portions of OU3, which relates to addressing contamination associated with the sediment/soil in the river areas, including the Maurice River, the Blackwater Branch of the Maurice River and their associated floodplains. Initial cleanup activities were completed for OU3 in December 2012. However, monitoring since that time has shown that certain areas of exposed sediment/soil of the Blackwater Branch floodplain have become re-contaminated with arsenic above the cleanup goals identified in the 1989 ROD due to arsenic in groundwater reaching the sediment/soil during the ongoing implementation of the OU2 remedy. As such, additional actions may be required to address this portion of OU3; alternatives are evaluated herein. This Proposed Plan does not fully address the Maurice River or the submerged sediment of the Blackwater Branch, which are also portions of OU3 of the site. These portions are still under review. OU4 of the site relates to Union Lake, an 870-acre impoundment on the Maurice River. The upstream remedial activities will be evaluated prior to proceeding

3

with active cleanup of the lake. Arsenic contamination in sediment has been found in the lake. Surface water samples had elevated arsenic concentrations only when agitated (mixed with contaminated sediment). Beach monitoring in Union Lake began in the early 2000s and will continue until it is concluded that there are no further impacts to the lake. To date, no unacceptable risks to beach users have been identified.

Future amendments to the 1989 ROD may be required, including for the remainder of OU3.

SITE BACKGROUND

Site Description

The Vineland Chemical Company Superfund site is located in the northwestern portion of Vineland, in Cumberland County, south central New Jersey, in an area of mixed industrial, low-density residential and agricultural properties (Figure 1). The site is bordered immediately to the north by other industrial properties and the Blackwater Branch, a perennial stream that flows westward to the Maurice River.

The Blackwater Branch of the Maurice River flows northeast to southwest, in proximity to, and partially through, the site itself. A floodplain lies immediately adjacent to the Blackwater Branch along the entire length of the tributary extending to the Maurice River. This area is the subject of this Proposed Plan.

Site History

The Vineland Chemical Company operated from 1949 to 1994 and produced arsenical herbicides and fungicides. There were seventeen buildings on the plant site, some of which were used by the Vineland Chemical Company for various manufacturing purposes.

As early as 1966, the New Jersey Department of Health observed untreated wastewater being discharged into unlined lagoons at the site. This wastewater was contaminated with arsenic at concentrations up to 67,000 parts per billion (ppb). Waste salts containing 1-2 percent arsenic were stored outside in uncovered piles. Precipitation dissolved some of these salts and carried them into the groundwater and eventually into nearby surface water bodies. Contaminated sediment was mapped 1.5 miles downstream in Blackwater

Branch to its confluence with the Maurice River and then 7.5 miles downstream to Union Lake.

The site was added to the EPA’s National Priorities List (NPL) in September 1984. A Remedial Investigation and Feasibility Study (RI/FS) was completed in 1989 to identify the types, quantities, and locations of contaminants, and to develop ways to correct the problems posed by the contaminants.

Based on the RI/FS findings, EPA implemented a number of response actions that included securing the site with a perimeter fence and removing thousands of gallons of arsenic solutions and demolition of eight buildings.

A ROD for the site was signed in 1989 and determined that actual or threatened releases of hazardous substances from the site, if not addressed by implementing the response actions selected in the ROD, may present an existing or potential threat to public health, welfare or the environment. The ROD divided the site into four operable units (OUs) as described in the “Scope and Role of Action” section above.

Enforcement History

Potentially responsible parties (PRPs) identified for the site include the Vineland Chemical Company and its owners.

In 1994, the PRPs entered into a judicial consent decree with EPA. The consent decree assured that the PRPs funded the remedial work to the maximum extent possible.

SITE CHARACTERISTICS

The site is located in the Atlantic Coastal Plain physiographic province, which consists of a seaward-dipping wedge of unconsolidated sediment (sand, silt, clay, and gravel) that range in age from Cretaceous to Quaternary periods. Locally, the site is situated on a relatively level plain that slopes slightly from the southeast toward the northwest with topographic elevations that range from 65 to 75 feet above mean sea level.

Groundwater levels vary seasonally at the site with an average of approximately 10 feet below ground surface (bgs), and a typical minimum and maximum of between 4 and 19 feet bgs. When the groundwater treatment

4

plant is not in operation, groundwater south of the Blackwater Branch moves in an east to west direction with groundwater discharging at several locations along Blackwater Branch. Under pumping conditions, the direction of flow is somewhat altered to a more southeast to northwest flow direction south of Blackwater Branch, and a northeast to southwest flow direction north of Blackwater Branch. Groundwater that is not captured by the recovery system discharges to Blackwater Branch. RESULTS OF THE REMEDIAL STUDIES

Implementation of 1989 ROD Remedy for OU3

The excavation and treatment of arsenic impacted sediment from the Blackwater Branch and its floodplain were carried out in four phases from 2006 through 2012. Phase I encompassed the area east of North Mill Road and adjacent to the chemical plant site. Phase II encompassed the area west of North Mill Road and east of Route 55. Phase III encompassed the area west of Route 55 and east of the Maurice River Parkway. Phase IV encompassed the stream and floodplain west of the Maurice River Parkway to the Maurice River. In each phase, the Blackwater Branch was diverted to a clean location before excavation of the contaminated material was performed. Once material with arsenic concentrations exceeding 20 milligrams/kilogram (mg/kg), the value identified in the 1989 ROD, was removed, the excavated area was backfilled with clean material and stream flow was restored to the re-constructed stream channel. Soon after arsenic excavation in the floodplain of Phases 1 and 2 was completed in 2009, iron staining along the banks and within the Blackwater Branch was observed in certain locations. Sediment and seep water samples taken at a few of these iron-stained locations were analyzed in 2010 to determine if these iron-stained sediment also contained arsenic. Phase 1 samples were taken after excavation, backfilling and flow had been restored to the channel. Phase 2 samples were collected after excavation and backfilling in the floodplain had occurred, but before flow was restored to the original creek channel. The sediment samples that were co-located with the seep samples contained arsenic just above the floodplain sediment goal of the 1989 ROD (20 mg/kg). These results provided evidence that arsenic is seeping

into the Blackwater Branch floodplain at some of the locations sampled even with the pump and treat system in operation, contaminating exposed sediment. The OU3 remedy was selected based on the assumption that groundwater discharging into the Blackwater Branch floodplain would not impact the exposed sediment. Sampling of surface sediment was performed between 2011 and 2012 along Phases 2, 3 and 4, soon after stream restoration and prior to re-diverting the surface water back to the stream. Samples were biased toward the iron-stained sediment. Results indicate that arsenic in surface sediment samples accumulated soon after restoration and concentrations exceed the 20 mg/kg ROD goal for exposed sediment. Due to extensive arsenic exceedances along the Phase 4 segment of the Blackwater Branch, surface water was not re-diverted back to this section of the Blackwater Branch. The Blackwater Branch was eventually re-diverted back to a stream alignment that was similar to the original but followed an alternate path around the areas where the arsenic exceedances were encountered. Additional sediment sampling was conducted in Phases 1 and 2 between 2013 and 2015. Samples were biased to locations that were iron-stained and were collected from floodplain areas as well as locations near the banks of the Blackwater Branch where sediment is likely to be exposed during periods of low water level conditions. During this time period, operation of the pump and treat system varied between full pumping, no pumping and partial pumping. Concentrations of arsenic in sediment samples exceeded 20 mg/kg while the pump and treat system was fully operational as well as while the pump and treat system was shut down. In summary, sediment samples collected between 2010 and 2015 demonstrated that groundwater that is discharging to the Blackwater Branch in certain areas is recontaminating the sediments due to localized geochemical conditions that result in the dissolved arsenic precipitating out as the groundwater discharges into the branch sediment. Over time, larger areas of sediment may become recontaminated. It should be noted that despite the elevated arsenic concentrations in the floodplain, surface water arsenic concentrations have not been found to be elevated. Bench Scale Studies

Once it was determined that implementation of the OU3 remedy would not prevent recontamination of the floodplain sediment/soil, preliminary bench scale

5

(laboratory) testing was conducted to evaluate the viability of in-situ (in-ground) treatment as a method of controlling recontamination. In-situ treatments evaluated at the bench scale focused on creating conditions for which the accumulation of arsenic in sediment would be unfavorable either by reducing the movement of arsenic to the sediment/soil of the floodplain or by reducing the availability of areas onto which arsenic can accumulate through bonding with the sediment. Results of the bench scale studies indicated that several methods of in-situ treatment can reduce arsenic accumulation in sediment/soil so that concentrations in the Blackwater Branch floodplain would remain below cleanup goals. These methods include in-situ treatment with oxygen (such as by air sparging or the use of peroxide), in-situ treatment with iron, and/or in-situ pH adjustment.

In 2015, pilot (in-field) testing of in-situ treatment options was initiated, and the preliminary results of this testing are favorable. Because the results show that the in-situ treatment is working, the pilot study will continue and will remain operational until an amended remedy is implemented.

PRINCIPAL THREATS

Although arsenic in groundwater is acting as a source of recontamination of the exposed sediment/soil of the Blackwater Branch floodplain, groundwater is generally not considered to be a source material under the conceptual definition of a principal threat (see related box “What is a “Principal Threat”?). The arsenic in groundwater can also be reliably immobilized through in-situ treatment. As such, the groundwater is not considered a principal threat waste for this OU of the site. SUMMARY OF SITE RISKS

As part of the FFS, human health and ecological risk evaluations were conducted for the exposed sediment/soil of the Blackwater Branch floodplain to estimate risks associated with current and future site conditions. Three separate areas with contamination were identified with unique geochemical conditions known as Areas A, B, and C (Figure 3).

Human Health Risk Assessment

As part of the FFS for OU3, a human health risk assessment (HHRA) process was used for assessing site-related cancer risks and non-cancer health hazards associated with exposure to arsenic in the sediment/soil. The four-step process is comprised of: Hazard Identification, Exposure Assessment, Toxicity Assessment, and Risk Characterization (see adjoining box “What is Risk and How is it Calculated” for more details on the risk assessment process).

The HHRA reviewed post-excavation exposed sediment/soil data collected between 2012 and 2015 in the Blackwater Branch floodplain against current risk-based screening levels (RSLs). A screening evaluation was conducted for the future recreational user, or recreator, in the Blackwater Branch floodplain to assess the protectiveness of the remedy that was selected in the original 1989 Record of Decision for OU3. Calculation of risk-based RSLs for sediment/soil (which looks at exposure through ingestion, dermal contact with and inhalation of contaminated sediment/soil) were based on standardized equations that combine exposure information and assumptions with available toxicity data. Recreator exposure parameters were used to best approximate site exposure during future recreational use of the Blackwater Branch. Any current site user (e.g., treatment plant

WHAT IS A "PRINCIPAL THREAT"?

The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by a site wherever practicable (NCP Section 300.430(a)(1)(iii)(A)). The "principal threat" concept is applied to the characterization of "source materials" at a Superfund site. A source material is material that includes or contains hazardous substances, pollutants or contaminants that act as a reservoir for migration of contamination to groundwater, surface water or air, or acts as a source for direct exposure. Contaminated groundwater generally is not considered to be a source material; however, Non-Aqueous Phase Liquids (NAPLs) in groundwater may be viewed as source material. Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained, or would present a significant risk to human health or the environment should exposure occur. The decision to treat these wastes is made on a site-specific basis through a detailed analysis of the alternatives using the nine remedy selection criteria. This analysis provides a basis for making a statutory finding that the remedy employs treatment as a principal element.

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worker or trespasser) would have less frequent exposures, and thereby lower risks, than these future receptors. A reasonable maximum exposure scenario of 4 hours per day and 40 days per year was considered, in line with the 1989 Baseline Risk Assessment’s evaluation of recreational use. The maximum detected arsenic concentrations in all three areas of the Blackwater Branch floodplain are greater than the human health-based RSLs, which indicates the potential for unacceptable risk and adverse health effects from recreational exposure to exposed Blackwater Branch sediment/soil. Additionally, the maximum concentrations of arsenic in all three areas of the Blackwater Branch floodplain exceed the site 1989 cleanup level of 20 mg/kg for arsenic in exposed sediment by an order of magnitude or more. A semi-quantitative screening evaluation was conducted for Area A of the Blackwater Branch floodplain. The results indicate that the current remedy is likely not protective of human health for a future recreator. The estimated cancer risk for a child and adult recreator utilizing the Blackwater Branch in this area would equal 2 x10-4, exceeding the 10-4 lifetime excess cancer risk end of the risk range. The non-cancer hazard estimate for a child recreator is 5, exceeding EPA’s non-cancer hazard index of 1.

Ecological Risk Assessment

A different approach was used in evaluating ecological risk associated with contamination in the exposed sediment/soil of the Blackwater Branch floodplain in comparison to the evaluation of human health risks. As is stated above, maximum concentrations of arsenic in all three areas of the Blackwater Branch floodplain exceed the site 1989 cleanup level of 20 mg/kg for arsenic in exposed sediment/soil by an order of magnitude or more. As such, an evaluation was conducted to determine whether cleanup of the floodplain to concentrations below the 1989 ROD goal would be protective of the environment. The floodplain soil is considered to be representative of a terrestrial environment, thus concentrations of arsenic were compared to EPA’s Ecological Soil Screening Level (Eco-SSLs), which are concentrations of contaminants in soil that are protective of ecological receptors that commonly come into contact with and/or consume biota that live in or on soil. As such, these values are presumed to provide adequate protection of

WHAT IS RISK AND HOW IS IT CALCULATED?

A Superfund baseline human health risk assessment is an analysis of the potential adverse health effects caused by hazardous substance releases from a site in the absence of any actions to control or mitigate these under current and future land uses. A four-step process is utilized for assessing site-related human health risks for reasonable maximum exposure scenarios. Hazard Identification: In this step, the contaminants of potential concern (COPCs) at the site in various media (i.e., soil, groundwater, surface water, and air) are identified based on such factors as toxicity, frequency of occurrence, and fate and transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility, persistence, and bioaccumulation. Exposure Assessment: In this step, the different exposure pathways through which people might be exposed to the contaminants identified in the previous step are evaluated. Examples of exposure pathways include incidental ingestion of and dermal contact with contaminated soil and ingestion of and dermal contact with contaminated groundwater. Factors relating to the exposure assessment include, but are not limited to, the concentrations in specific media that people might be exposed to and the frequency and duration of that exposure. Using these factors, a “reasonable maximum exposure” scenario, which portrays the highest level of human exposure that could reasonably be expected to occur, is calculated. Toxicity Assessment: In this step, the types of adverse health effects associated with chemical exposures, and the relationship between magnitude of exposure and severity of adverse effects are determined. Potential health effects are chemical-specific and may include the risk of developing cancer over a lifetime or other non-cancer health hazards, such as changes in the normal functions of organs within the body (e.g., changes in the effectiveness of the immune system). Some chemicals are capable of causing both cancer and non-cancer health hazards. Risk Characterization: This step summarizes and combines outputs of the exposure and toxicity assessments to provide a quantitative assessment of site risks for all COCs. Exposures are evaluated based on the potential risk of developing cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancer is expressed as a probability. For example, a 10-4 cancer risk means a “one in ten thousand excess cancer risk;” or one additional cancer may be seen in a population of 10,000 people as a result of exposure to site contaminants under the conditions identified in the Exposure Assessment. Current Superfund regulations for exposures identify the range for determining whether remedial action is necessary as an individual excess lifetime cancer risk of 10-4 to 10-6, corresponding to a one in ten thousand to a one in a million excess cancer risk. For non-cancer health effects, a “hazard index” (HI) is calculated. The key concept for a non-cancer HI is that a “threshold” (measured as an HI of less than or equal to 1) exists below which non-cancer health hazards are not expected to occur. The goal of protection is 10-6 for cancer risk and an HI of 1 for a non-cancer health hazard. Chemicals that exceed a 10-4 cancer risk or an HI of 1 are typically those that will require remedial action at the site.

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terrestrial avian and mammalian receptors. The EPA Eco SSLs for arsenic are 18 mg/kg for plants, 43 mg/kg for avian receptors and 46 mg/kg for mammalian receptors.

Comparison of these screening levels to the 1989 ROD goal of 20 mg/kg for arsenic shows that this value is protective for avian and mammalian receptors. The only ecological value in exceedance of 20 mg/kg is the value that was derived to be protective to plants (18 mg/kg). However, arsenic concentrations at or below background values (20 mg/kg in 1989, 19 mg/kg currently) are not considered COPCs. Conversely, since concentrations above 46 mg/kg are present, this review shows that there is a potential risk to ecological receptors.

Risk Assessment Summary

It is EPA’s judgment that the Preferred Alternative identified in this Proposed Plan, or one of the other active measures considered in this Proposed Plan, is necessary to limit potential human health and ecological risks from actual or threatened releases of hazardous substances into the environment.

FOCUSED FEASIBILITY STUDY

The FFS was prepared to evaluate alternative remedial actions for OU3. During the FFS phase, remedial action objectives (RAOs) are developed, preliminary remediation goals (PRGs) are identified, technologies are screened based on overall implementability, effectiveness and cost, and remedial alternatives are assembled and analyzed in detail with respect to the nine criteria for remedy selection under the NCP at 40 C.F.R. Part 300.430.

Remedial Action Objectives

RAOs describe what the proposed remedy is expected to accomplish. These objectives are based on available information and standards such as applicable or relevant and appropriate requirements (ARARs), to-be-considered standards and guidance, and site-specific risk-based levels.

The 1989 ROD identified the following RAO for the sediment in OU3:

• Minimize public exposure, either through

containment, removal, or institutional controls, for those areas with unacceptably high sediment arsenic concentrations.

This overall RAO for OU3 remains in effect. The specific RAOs for the remedial alternatives discussed in this Proposed Plan are:

• Reduce concentrations of arsenic in theexposed sediment/soil in the BlackwaterBranch floodplain to below acceptable levels ofrisk.

• Prevent recontamination of exposedsediment/soil of the Blackwater Branchfloodplain from site-related groundwatercontamination.

Due to the existence of larger groundwater contamination issues at this site, it is EPA’s expectation that the remedy described in this Proposed Plan will be revisited at a future date. Therefore, this action is considered an interim remedial action.

Preliminary Remediation Goal

To achieve RAOs, EPA has selected a soil cleanup goal for the exposed sediment/soil. The soil cleanup goal for the COPC is consistent with New Jersey Residential Direct Contact Soil Remediation Standards (NJRDCSRS). Therefore, the PRG for the COPC in exposed sediment/soil of the Blackwater Branch floodplain is as follows:

• Arsenic: 19 mg/kg

The 1989 ROD identified a Preliminary Remediation Goal of 20 mg/kg for arsenic in exposed sediment. Since then, the state of New Jersey has conducted a much more robust study of statewide levels of arsenic in soil, and from this study a statewide concentration of 19 mg/kg has been established. EPA has evaluated the protectiveness of 19 mg/kg and the PRG for arsenic in the exposed sediment/soil has been modified to meet the current New Jersey Soil Remediation Standard.

The PRG will become the final remediation goal when EPA makes a final decision to select an amended remedy for the exposed sediment/soil of the Blackwater Branch floodplain, after taking into consideration public comments.

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Remedial Alternatives

CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that remedial actions be protective of human health and the environment, be cost-effective, and use permanent solutions, alternative treatment technologies, and resource recovery alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a preference for remedial actions which use, as a principal element, treatment to permanently and significantly reduce the volume, toxicity or mobility of the hazardous substances, pollutants, and contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a remedial action must require a level or standard of control of the hazardous substances, pollutants, and contaminants, which at least attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4). Remedial alternatives for the site are summarized below. Capital costs are those expenditures that are required to construct a remedial alternative. Operation and maintenance costs are those post-construction costs necessary to ensure or verify the continued effectiveness of a remedial alternative and are estimated on an annual basis. Present worth is the amount of money which, if invested in the current year, would be sufficient to cover all the costs over time associated with a project, calculated using a discount rate of seven percent and a 10-year time interval. Construction time is the time required to construct and implement the alternative and does not include the time required to design the remedy, negotiate performance of the remedy, or procure contracts for design and construction.

• Alternative 1: No Further Action

• Alternative 2: Ongoing Hot Spot Excavation

• Alternative 3: In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring

Alternative 1 - No Action The NCP requires that a “No Action” alternative be evaluated to establish a baseline for comparison with other remedial alternatives. Under this alternative, no further action would be implemented, and the current status of the site would remain unchanged. A Classification Exception Area for the site already exists to restrict use of groundwater. Signs are posted in

accessible areas of Blackwater Branch and the Maurice River advising the public that sediment is contaminated with arsenic and there are risks associated with prolonged exposure of arsenic. With the exception of the existing security fences, engineering controls would not be implemented to prevent site access or exposure to site contaminants.

Total Capital Cost: $0 Annual O&M: $0 Total Present Net Worth : $0 Timeframe: 0 years Alternative 2 – Ongoing Hot Spot Excavation This alternative consists of periodic excavation and off-site disposal of the exposed sediment/soil of the Blackwater Branch floodplain as the arsenic concentrations exceed the PRG. Excavated sediment/soil would be transported and disposed of off-site. The sediment/soil would be sampled to determine if they need to be disposed of as either hazardous waste or non-hazardous waste. Treatment of sediment/soil, if needed, would be conducted at and by the approved disposal facility. Total Capital Cost: $1,160,646 Annual O&M: $4,642,584 Present Worth Cost: $33,768,213 Construction Time Frame: Constant Alternative 3 – In-Situ Treatment, Hot Spot

Excavation, and Performance Monitoring

This alternative consists of installation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil to concentrations above PRGs, hot-spot excavations to remove exposed sediment/soil in the Blackwater Branch floodplain above PRGs, and performance monitoring to assure the remedy is effective and assess the need for additional in-situ treatment and/or excavation. In-situ technologies are those technologies that are implemented in place, rather than removing the contamination and treating it. The in-situ technology used may vary across the site and will depend on the geochemistry and subsurface conditions in each particular location. Examples of such technologies include air sparging in iron rich groundwater environments and iron chloride injection

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in addition to air sparging or peroxide injection in iron poor groundwater environments. In-situ technologies may also include pH adjustments and/or the installation of material into the ground which will intercept the groundwater flow and passively capture the contamination, also known as ‘reactive barriers’. Final selection of the in-situ treatment technology appropriate for each area of the site will be made after further studies during remedial design. In addition, the need for excavation of the exposed sediment/soil before and/or after in-situ treatment for each area of the site will be determined during the remedial design and further refined during

implementation of the remedial action through performance monitoring. Total Capital Cost: $7,281,988

Annual O&M Year: $745,569 Present Worth Cost: $14,897,663 Construction Time Frame: 1 year COMPARATIVE EVALUATION OF

ALTERNATIVES

EPA uses nine criteria to evaluate the remedial alternatives individually and against each other to select a remedy. This section of the Proposed Plan profiles the relative performance of each alternative against the nine criteria, noting how it compares to the other options under consideration. Each alternative must meet the first two threshold criteria, which are overall protection of human health and the environment, and compliance with ARARs. Alternatives that meet the threshold criteria are then analyzed against five primary balancing criteria: long-term effectiveness and permanence; reduction to toxicity, mobility, or volume through treatment; short-term effectiveness; implementability; and cost. State and community acceptance are modifying criteria that are also considered in remedy selection. A detailed analysis assessing the alternatives against each of the nine evaluation criteria is in the FFS.

Overall Protection of Human Health and the

Environment

Alternative 1 does not protect human health and the environment because no action is taken to prevent exposure to sediment/soil that exceeds risk based cleanup levels for arsenic. Alternative 2 is protective of human health and the environment because sediment/soil is removed as it reaches arsenic concentrations that exceed the risk based cleanup goals. Alternative 3 is protective of human health and the environment because in-situ treatment systems are installed and operated that prevent recontamination of sediment/soil with arsenic, and sediment/soil currently exceeding risk based arsenic concentrations are removed and disposed of off-site.

THE NINE SUPERFUND EVALUATION CRITERIA

1. Overall Protectiveness of Human Health and the Environment evaluates whether and how an alternative eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or treatment.

2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) evaluates whether the alternative meets federal and state environmental statutes, regulations, and other requirements that pertain to the site, or whether a waiver is justified. 3. Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human health and the environment over time.

4. Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the amount of contamination present. 5. Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the alternative poses to workers, the community, and the environment during implementation. 6. Implementability considers the technical and administrative feasibility of implementing the alternative, including factors such as the relative availability of goods and services. 7. Cost includes estimated capital and annual operations and maintenance costs, as well as present worth cost. Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are expected to be accurate within a range of +50 to -30 percent.

8. State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses and recommendations, as described in the RI/FS and Proposed Plan.

9. Community Acceptance considers whether the local community agrees with EPA's analyses and preferred alternative. Comments received on the Proposed Plan are an important indicator of community acceptance.

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Compliance with ARARs

Alternative 1 (No action) would not comply with ARARs in that it would leave exposed sediment/soil in place that exceed NJRDCSRS and pose unacceptable risk to human health and the environment.

Alternatives 2 and 3 provide compliance with chemical-specific ARARs by removing contaminated soil above NJRDCSRS. Alternative 2 would accomplish this by removal of sediment/soil that exceeds ARARs, and Alternative 3 would accomplish this by in-situ treatment that would prevent groundwater from recontaminating the sediment/soil. Location-specific ARARs and Action-specific ARARs would both be met by proper design and implementation of the respective components such as general construction standards and waste handling requirements. The Location-specific ARARs and Action-specific ARARs for the disposal phase would be met with proper selection of the disposal facility.

Long-Term Effectiveness and Permanence

Although the three alternatives are interim remedial actions, they were evaluated for long-term effectiveness and permanence.

Alternative 1 does not provide adequate controls of risks to human health over the long-term because there is no mechanism to prevent future exposure.

Alternative 2 is only effective in the long-term with a high level of constant maintenance. It does not treat the source of contamination, and although steps would be taken to protect the surrounding community, there would be nearly continuous operation of construction equipment and hauling of contaminated soil off-site for an indefinite period of time.

Alternative 3 is effective in the long-term in that it prevents recontamination of the exposed sediment/soil in the Blackwater Branch floodplain.

Reduction of Toxicity, Mobility, or Volume through

Treatment

Alternatives 1 and 2 do not reduce the toxicity, mobility, or volume of contaminants through treatment and therefore do not meet EPAs preference for treatment.

Alternative 3 does not reduce the overall volume of arsenic but does reduce the mobility of arsenic in the groundwater, which reduces the volume entering the Blackwater Branch floodplain. This effectively reduces the toxicity of the groundwater entering the Blackwater Branch floodplain.

Short-Term Effectiveness

There would be no short-term impact to the local community or the environment for Alternative 1.

The construction and implementation activities involved in Alternative 2 would be frequent and would have almost continuous impact on the local community with truck traffic to haul contaminated sediment/soil for off-site disposal.

Alternative 3 would have some impacts to the nearby community due to truck traffic to haul contaminated sediment/soil off-site and drilling activities to install the in-situ treatment systems. However, these impacts would be relatively short term and ongoing long term treatment activities at the site are expected to have minimal impact to the community.

Implementability

All the alternatives are easily implemented. There are no special techniques, materials, or labor required to implement Alternative 2.

Cost

For Alternative 2, each time sediment/soil needs to be excavated it is estimated it will cost $1,160,000. Assuming this has to be performed every 3 months, that is an annual cost of $4,642,584. The present worth cost over a 10-year period is estimated to be $33,768,213.

The estimated capital cost of Alternative 3 is $7,281,988. The annual O&M cost is estimated to be $745,569 the first year and an annual cost of $557,670 for the following years. This alternative also includes an annual monitoring cost of $213,438 the first year, $135,461 the second year and $95,663 for the following years. The 10-year present worth value of this alternative is $14,897,663.

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State Acceptance

The State of New Jersey concurs with EPA’s Preferred Alternative as presented in this Proposed Plan.

Community Acceptance

Community acceptance of the Preferred Alternative will be evaluated after the public comment period ends and will be described in the ROD Amendment. Based on public comment, the Preferred Alternative could be modified from the version presented in this proposed plan. The ROD Amendment formalizes the selected remedy after EPA has considered all comments received during the public comment period.

PREFERRED ALTERNATIVE

The Preferred Alternative for achieving remedial action objectives for the exposed sediment/soil of the Blackwater Branch floodplain impacted by site-related contamination is Alternative 3 (In-Situ Treatment, Hot Spot Excavation, and Performance Monitoring). This alternative consists of installation of in-situ treatment technologies to prevent recontamination of the exposed sediment/soil to concentrations above PRGs, excavation of localized areas of sediment/soil in the Blackwater Branch floodplain with concentrations of contaminants above PRGs, and performance monitoring to assure the remedy is effective and assess the need for additional in-situ treatment and/or excavation. This is considered an interim remedial action that will be revisited at a future date once the long-term effectiveness as a part of the remedy for all operable units of the site is evaluated.

The in-situ technology that will be used depends on the geochemistry and subsurface conditions in each particular location. The actual technology will be selected during the Remedial Design. For the purposes of cost estimation the following were used as representative technologies: air sparging in iron rich groundwater environments; iron chloride injection in addition to air sparging in iron poor groundwater environments; sodium bicarbonate or sodium hydroxide injections for pH adjustments. As noted above, the final selection of the in-situ treatment technology appropriate for each area of the site will be made after further studies during remedial design.

The selection of the Preferred Alternative is accomplished through the evaluation of the nine criteria as specified in the NCP. Alternative 3 satisfies the two threshold criteria and achieves the best combination of the five balancing criteria of the comparative analysis. This alternative is preferred because it will achieve the RAOs in the shortest amount of time. Monitoring will provide the data to ensure that the RAOs and PRGs are achieved.

The EPA and NJDEP expect the Preferred Alternative to satisfy the following statutory requirements of CERCLA Section 121(b): 1) be protective of human health and the environment; 2) comply with ARARs; 3) be cost effective; 4) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable; and 5) satisfy the preference for treatment as a principal element. EPA will assess the modifying criteria of community acceptance in the Record of Decision Amendment following the close of the public comment period.

FOR FURTHER INFORMATION

The Administrative Record file, which contains copies of the Proposed Plan and supporting documentation is available at the following locations:

EPA Region 2 Superfund Records Center

290 Broadway, 18th Floor New York, New York 10007-1866 (212) 637-4308 Hours: Monday-Friday – 9 A.M. to 5 P.M.

Vineland City Library 1058 East Landis Ave. Vineland, New Jersey 08360 For Library Hours: http://www.vinelandlibrary.org/

In addition, select documents from the administrative record are available on-line at:

www.epa.gov/superfund/vineland-chemical In addition, select documents from the administrative record are available on-line at:

http://www.epa.gov/region2/superfund/npl/vineland/

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1 23 4 56 3 78 9 : Figure 1: Site Location

Figure 2: Operable Unit Identification

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Figure 3: Delineation of Areas A, B and C

Attachment B

Public Notice

A spokeswoman saidthe Progresso brand willcontinue making soupin other plants. ButKelsey Roemhildt ofGeneral Mills couldn’tsay how many of thatgiant food company’s 30other production plantscook Progresso soups.

“As a category, cannedsoup has been decliningfor some time,” she said.

Brian String, presi-dent of UFCW Local152, said his union rep-resents about 275Progresso workers. Hesaid the closingannouncement camejust two months afterunion members ratifieda four-year contract.

“People here areangry, and I don’t blamethem,” String saidThursday. “During fourmonths of bargaining,the company neverhinted that this plantmight close. Its negotia-tors never asked forconcessions that ourmembers surely wouldhave granted to keepthe plant open.”

State Sen. Jeff VanDrew, D-Cape May,Cumberland, Atlantic,called the announce-ment “heartbreaking”but held out hope itcould change.

“We must keep inmind that the plant isnot going to close tom-orrow. We have until nextsummer to see if theplant can be retooled orchanged, if products canbe changed or anything,”he said, although headded that officials willlook for other compa-nies to fill the plant andrestore some jobs.

But the company’shighlighting its Vine-land roots in those adshas a bad taste to himnow.

“The point was thatthis was a homemadetype of soup, made righthere in good oldVineland,” he said. “It’smind-boggling that theycould run those ads andall of a sudden decide toclose that plant.”

Progresso’s SouthJersey roots were high-lighted last year in ads:“In Vineland, it’s allabout the flavor.”

Camden-based Camp-bell’s Soup Co. com-plained those commer-cials falsely impliedmost Progresso soupswere Vineland-madewith local produce. Anarm of the Council ofBetter Business Bureausruled the commercialsgave an “unsupportedmessage that most ...ingredients are sourcedin Vineland.” GeneralMills had alreadystopped the ads at that

time.U.S. Rep. Frank

LoBiondo, R-2nd, is notoptimistic about con-vincing General Mills tostay in Vineland.

“They made it prettyclear to (Lt. Gov. KimGuadagno) and me andthe union president thatthe decision is irre-versible,” said LoBiondo,who used to deliver toProgresso and haul outloads of soup when heworked at his family’sVineland trucking firm.

“It’s devastating news,and it’s unconscionablehow poorly they havehandled this,” LoBiondosaid. “They really justhit us with a 2-by-4, andthat’s not the way to dobusiness. It’s not theway to treat employeesat a plant that was prof-itable for a long time.”

Guadagno alsosounded resigned toProgresso’s departurebut said its facilitiescould still be attractive

to other companies.“We’re confident we

can fill this plant,” shesaid via Twitter.

Still, Roemhildt, theGeneral Mills spokes-woman, called the clos-ing “tentative,” not final.

“We’ll start back upon our regularly sched-uled shifts Monday, andwe hope to begin dis-cussions with theunions in the comingweeks,” she said.

String called therecent contract negotia-tions “standard, toughbargaining, like it alwaysis.” He added that theworkers even got raisesin their new deal.

But now, “I feel like(the closing) is a donedeal,” he said. “They’veclosed other plants,mostly union plants.”

String said Progresso“pays people livingwages,” but they’re “allover the board. ... A lotof it is predicated on thelongevity they have with

the company.”Progresso’s own

longevity dates to 1927,when the foundingTaormina and Uddofamilies incorporated it.In 1942, they openedtheir first Vineland planton Chestnut Avenue,and started cookingminestrone, lentil andother soups favored byItalian-Americans.

The families soldProgresso in 1969; ayear later, the companybuilt its current Vine-land plant. It has beenbought and sold by acollection of big foodcompanies, includingPillsbury, Pet andGeneral Mills, whichbought the brand in2001.

Roemhildt said theclosing is no reflectionon the workers.

“It’s about excesscapacity in our soupnetwork,” she said.Contact: [email protected]

Christie’s plan woulddistribute aid on a per-student basis, with eachstudent worth about$6,600 in state aid. Underthat plan, the townshipwould get an extra $8.7million per year.

School board PresidentJames Galvin said theboard cut $8 million thisyear to stay within thestate spending cap.

“We are one of theworst in underfunding,”he said. “We havebegged and begged, butit falls on deaf ears.”

Sweeney, a Democrat,said his plan is more fair,because it would fundevery district at 100 per-cent of what it shouldreceive under the formu-la, though he said thatwould mean some dis-tricts that have been over-funded would lose aid.

“But how can you arguewith everyone beingtreated the same?” heasked.

The plan would costan additional $500 mil-lion, phased in as $100million per year overfive years.

Sen, Jim Whelan, D-Atlantic, said the Repub-lican governor’s planmakes a good soundbite but is not equitable.

“Kids from Pleasant-ville had higher needsthan kids from Lin-wood,” he said.

Sweeney asked officialsto promote the plan toresidents and have themwrite to their legislators.

Mayor James “Sonny”McCullough said he gota call from the Governor’sOffice asking him tosupport Christie’s plan.

“I’ll support anythingthat can pass,” he said.

Sweeney said hebelieves his plan hasmore support.

Officials talked abouthow as a Pinelandsgrowth area the town-ship expanded rapidly inthe 1990s, but state aidnever kept up.

“At one time, we werethe fastest-growing mun-icipality in the state,” saidTownship AdministratorPeter Miller. “Now we’rein a big (financial) hole.”

Board member PeteCastellano said he isconcerned that even if anew formula passes, theLegislature may notfund it in the budgetprocess, which is whathappened with the cur-rent formula, especiallyduring the recession.

Castellano and boardmember Justin Riggssaid after the meetingthat the full board willdiscuss the issue at apublic meeting to see ifmembers want to sup-port Sweeney’s bill.Contact: [email protected]

had not been located,police said.

Using a search war-rant, officers found twohandguns inside theresidence, police said.

Tamera Poprik ran tothe store only to returnto find police and SWATteam members canvass-ing her street. Poprikhad left her three boysat home in the unitabove the incident.

“I went to the storeand came back to this,”said Poprik, 31, as shetried to talk to police tolocate her children. “Ijust want to get my chil-dren.”

Poprik was reunitedwith them after abouthalf an hour.

“When I saw them, I

had to touch them,”Poprik said. “I’m happythis ended without anyincident. This is usuallya very peaceful street.When it was going on, Ihad all of my neighborscalling me and texting.”

Poprik described thesuspect as a quiet per-son who had recentlymoved in.

During the incident,Ventnor Avenue wasclosed from RaleighAvenue to ColumbiaAvenue.

“I woke up to thesound of the police say-ing come out with yourhands up,” said MichaelFitchett, Poprik’s 14-year-old son. “I tried toprepare my brothers forwhat was going on. Itried to stay calm.Luckily, we got out ofthere.”

Mazur praised thedepartment’s trainedpersonnel and equip-ment, including thearmored rescue vehicle.

“You may be in a per-sonal crisis, but if you

comply with the policeofficers, they are notthere to hurt you,” saidMazur, who added theneighbors were clap-ping and saying thankyou after Holley was

apprehended.Contact: [email protected] @ACPressHubaContact: [email protected] @ACPressJackson

THE PRESS OF ATLANTIC CITYAA88 • FRIDAY, JULY 22, 2016 LOCAL

SWATContinued from A3

SCHOOL AIDContinued from A3

VIVIANA PERNOT / STAFF PHOTOGRAPHER

The SWAT team rescued Vincent Poprik, left, 10; Michael Fitchett, 14; and Nick Poprik, right,11. Tamera Poprik, 31, of Atlantic City, says of her kids, ‘When I saw them, I had to touchthem. I’m happy this ended without any incident. This is usually a very peaceful street.’

CLOSINGContinued from A1

CRAIG MATTHEWS / STAFF PHOTOGRAPHER

Nelly Lorenzana, of Vineland, is one of hundreds of workers affected by the Progresso plant’splanned closing in 2017. General Mills spokeswoman Kelsey Roemhildt says, ‘We’ll start backup on our regularly scheduled shifts Monday, and we hope to begin discussions with theunions in the coming weeks.’More photos and a video are with this story at PressofAC.com.

LANDISAVENUE

SOUTH

WEST

BOULEVA

RD

DELSEADRIVE

6TH

STRE

ET

0 500FEET

CHESTNUTAVENUEWALNUT ROADELMER ROAD

ALMONDSTREETGeneral Mills/Progresso plant

V I N E L A N D

EHTAtlanticCityAtlanticOcean

Delaware Bay

HamiltonTwp. ATLANTIC

COUNTY

NEW JERSEY

CAPE MAYCOUNTY

CUMBERLANDCOUNTY

KRISHNAMATHIAS / PRESS GRAPHIC

VINELAND

MillvilleBridgeton

BRIAN IANIERIStaff Writer

WEST GOSHEN, Pa. —A woman who hasstolen nearly $3,000worth of Wawa coffeeover the past year maybe losing sleep at night.

Authorities say theyhave pictures of her andare asking for help toidentify her.

Police said the womanstole bagged coffee fromconvenience stores 40 to50 times in New Jersey,Pennsylvania, Delawareand Maryland.

“Wawa believes thethefts began in early2016 and are ongoing,”the department inChester County said.

The woman is appar-ently not drinking thecoffee, though. Policesaid she steals bags ofcoffee from one storeand returns them toanother Wawa for cash.

“In several of the

thefts inMarch andApril, thefemale iswearingscrubs, andit is possibleshe is a trav-eling health

care worker,” police said.Wawa surveillance

cameras captured atleast two different vehi-cles the woman hasdriven: a silver sedanand a maroon sport util-ity vehicle.

Anyone with informa-tion is asked to callpolice at 610-696-7400.

Wawa has more than650 convenience stores inNew Jersey, Delaware,Maryland, Pennsylvania,Virginia and Florida. It’sthe 36th largest privatefirm in America with near-ly 27,000 employees andabout $9 billion in rev-enue, according to Forbes.Contact: [email protected]

Wawa has 4-state huntin yearlong coffee caper

SUSPECT

Attachment C

Public Meeting Transcripts

1 1 VINELAND CHEMICAL COMPANY SUPERFUND SITE 2 BLACKWATER BRANCH EXPOSED SEDIMENT/SOIL 3 PUBLIC MEETING 4 5 - - - 6 Monday, August 8, 2016 7 - - - 8 9 Hearing held in the above-captioned matter at Vineland City Hall - 10 City Council Chambers, 640 East Wood Street, Vineland, New Jersey, 08360 at 6:30 p.m., there 11 being present: 12 13 WANDA AYALA, COMMUNITY INVOLVEMENT COORDINATOR 14 MICHAEL SIBAK, ACTING BRANCH CHIEF 15 STEPHANIE VAUGHN, ACTING SECTION CHIEF 16 HUNTER YOUNG, REMEDIAL PROJECT MANAGER 17 ABBEY STATES, HUMAN HEALTH RISK ASSESSOR 18 19 20 21 - - - 22 23 24 25

2 1 WANDA AYALA: Thank you for coming to 2 our meeting. This meeting is to discuss the 3 proposed plan for the Vineland Chemical Company 4 Superfund Site. As you guys know, the public 5 comment period is from July 22nd through August 6 22nd. We're required by Superfund Law to have a 7 transcript of these proceeding. That's why we 8 have the stenographer, Kate, here recording it 9 for us. I'm accompanied today by Hunter Young, 10 who is the project manager for the Vineland 11 Chemical Site. We have Stephanie Vaughn, who is 12 the acting chief for the Mega Projects Section, 13 Michael Sivak, who is acting branch chief for 14 the Special Projects Branch, and we have Abbey 15 States, who is our risk assessor. 16 I'd like to acknowledge any local 17 officials, besides Dale, that are attending. 18 Please put your phones on vibrate so we don't 19 disrupt the meeting and we're going to take 20 comments and questions after the presentation. 21 STEPHANIE VAUGHN: Hi, everyone. I'm 22 just going to very quickly go through the 23 Superfund process. This site is on the national 24 priorities list, otherwise known as the 25 Superfund List, and there is a lengthy process

3 1 for determining if a site is eligible to be put 2 on the list and be eligible for federal funds 3 and efforts, and then there's a lengthy process 4 once the site is on the list. So basically we 5 start out with a preliminary assessment and site 6 inspection and determine if it warrants being on 7 the list. This particular site, the Vineland 8 Chemical, was listed way back in the '80s. So 9 this has been on the Superfund List for a very 10 long time. 11 Once it is determined that it is on the 12 list, we initiate what's called a remedial 13 investigation where we investigate the site. We 14 look at all the different media, the soil, the 15 sediment, the groundwater, whatever is 16 appropriate, the surface water, and we determine 17 the nature and extent of the contamination. We 18 determine where the contamination came from and 19 where it is going. We also do things like look 20 at the site history to determine how the 21 contamination got there, what the operations of 22 the facility were, what the ownership history 23 was. We look for parties that may be 24 responsible for the contamination and try to 25 both hold them responsible and also to gain

4 1 information from people who may have been 2 involved, so that we just gain an understanding 3 of what happens at the site and what we may 4 expect to find. Then we follow it up with 5 appropriate investigations to see what is 6 present. 7 Once we finish that, we also do a risk 8 assessment during that process. We determine 9 the risk posed by that site to both human health 10 and the environment. Once we complete that 11 process, assuming we find there are 12 unacceptable, then we do what's called a 13 Feasibility Study. We determine how the 14 contamination at the site should be addressed. 15 We evaluate a number of options, including no 16 action. We would do that whether there were 17 risks or not, but we evaluate a series of 18 remedies for the site, and then we, EPA, come up 19 with what we think is the best option for the 20 site. Then we put out what's called a proposed 21 plan and that is the point in the process that 22 we are at now. You may have all seen or have 23 copies of the proposed plan for this part of 24 this site. Hunter will get into that into more 25 detail. This site was divided into several

5 1 different pieces or operable units. 2 With the proposed plan, there's a 30-day 3 public comment period where people can read 4 about it. They can ask us questions. We hold 5 this public meeting. They can submit comments, 6 either verbally or in writing. And at end of 7 that 30-day process or however long it ends up 8 being, we issue what's called a Record of 9 Decision and that is our path forward for that 10 site or the section of the site. 11 In this particular case, what we are 12 looking to do is actually an amendment to the 13 original Record of Decision for this site that 14 was signed in '89. So then once we make a 15 determination on how to proceed, we move into 16 remedial design and remedial action stage. Once 17 we sign the Record of Decision, we will start 18 designing the remedy, figuring out all the 19 details of how we actually implement what might 20 be a conceptual idea in the Feasibility Study, 21 and then we implement that in remedial action. 22 Finally, at some point we finish our 23 work, construction completion. We go to 24 operations and maintenance as necessary and 25 eventually the site may be deleted from the

6 1 Superfund List, if possible. Throughout this 2 whole process, there is community involvement 3 and that's a key part of the process, to hear 4 what the public has to say and their input. 5 People have lived in this community for a long 6 time, and they really know things about the area 7 and about the site and about potential future 8 uses, and many other things that we just can't 9 know. So it's a valuable part of our process, 10 and we also try to keep in mind re-use of the 11 site throughout the whole process. That's 12 ultimately what we want to do, return these 13 sites to productive use for the communities. I 14 think that's it. 15 HUNTER YOUNG: So that brings us here to 16 Vineland and the Vineland Chemical Company 17 Superfund Site. More specifically, here in 18 Vineland, we have the site itself right here and 19 we're looking at the Blackwater Branch today. 20 That's the part of the site we're going to be 21 talking about. Here you have the Maurice River, 22 which that drains into, and that actually leads 23 to Union Lake. The Vineland Chemical Company is 24 an old herbicide and fungicide plant, started 25 operations in 1949 and operated until 1994. In

7 1 the '60s, New Jersey Department of Health 2 observed some untreated wastewater dumping into 3 some unlined lagoons. This resulted in some 4 contamination in of the groundwater, which 5 eventually contaminated surface water bodies, 6 and the soil in the surrounding area became 7 contaminated. 8 Eventually, in 1989, we signed a Record 9 of Decision outlining a clean up for the site. 10 Here's a picture taken quite a while ago, 11 probably '90s. You can see Vineland Chemical 12 Site is here. This is the Blackwater Branch, 13 eventually leading out to the Maurice River. So 14 the Record of Decision broke the site up into 15 four different operable units. Operable units 16 are ways that EPA breaks Superfund sites, breaks 17 it down categorically, to make it more 18 manageable. We break them down by area: North, 19 south, east, west. We break it down by media. 20 So maybe it is groundwater, surface water, air. 21 For Vineland Chemical, we broke it into four 22 sites: First, site soil; second, groundwater; 23 third, the river area and sediments, which is 24 Blackwater Branch and the Maurice River; and 25 fourth, Union Lake. Here's a little diagram of

8 1 the different operable units. You can see a 2 groundwater plume over here. That's Unit 2. 3 The site itself over here, Unit 1. Here is 4 Blackwater Branch and Maurice River. That's 5 Unit 3. Downstream you've got Union Lake. 6 So just to talk a little bit more about 7 the site history, in 1984, it was added to the 8 National Priorities List, as Stephanie mentioned 9 earlier. In 1989, signed the ROD or Record of 10 Decision. In March of 2000, we started 11 groundwater pump-and-treat to contain the 12 groundwater plume and contain contamination and 13 treat that groundwater. In December 2007, we 14 completed cleaning the soil on site and we began 15 cleaning up Blackwater Branch. So we went in 16 and we dredged the river. However, in 2010, we 17 found recontamination happening. We found some 18 seeps in groundwater discharging out of the 19 floodplain and recontaminating those sediments. 20 In 2012, we finished the clean up of Blackwater 21 Branch that was outlined in the original Record 22 of Decision. In 2014, we transferred the 23 groundwater treatment to the State of New 24 Jersey, and then here we are today moving 25 forward to the proposed plan, which is going to

9 1 address that recontamination that we talked 2 about earlier. 3 Here's a picture of what it looks more 4 like today. Here is the site now. Some of 5 these buildings are actually gone now. Here's 6 Blackwater Branch. You can see how it's 7 engineered. This is actually what we did while 8 we were realigning this draining. We built a 9 new stream channel and then took the old stream 10 channel, cleaned it out. Then, eventually, 11 after this photo was taken, set that stream back 12 into its old channel. So we are here now to do 13 this ROD Amendment because we found 14 recontamination and we found that we need to 15 make a decision to change that remedy in order 16 to address the recontamination. The Record of 17 Decision documents remedial action. The ROD 18 Amendment is when a fundamental change needs to 19 be made to the remedy and that's what we believe 20 needs to happen. And, specifically, within 21 Operable Unit 3, which is the river area 22 sediment. We're specifically talking about 23 Blackwater Branch and just the exposed sediment 24 in Blackwater Branch. This is where we kept 25 seeing these seeps of recontamination.

10 1 We did some sediment sampling between 2 2010 and 2015, and we confirmed that 3 recontamination was happening. That sampling 4 led us to point out three distinct areas. We've 5 been calling them Areas A, B, and C. These are 6 three areas of our main focus, but there is the 7 option of other areas being included. We looked 8 at these three areas and we completed some bench 9 scale and pilot studies. These are test things 10 that you do in a laboratory and small tests in 11 the field to determine the effectiveness of 12 different treatments. We used this information 13 to develop Focus Feasibility Study. Focus 14 Feasibility Study outlines several different 15 remedial actions that we can take and compares 16 them against each other to see which one is most 17 effective. We also looked at risk. We looked 18 at how contamination of the site effects human 19 health, and we looked at how it effects 20 ecological health. 21 Then we outlined goals and objectives 22 for our Record of Decision Amendment. We 23 decided one of our main goals was going to be 24 reducing arsenic contamination in the sediment 25 and, second, would be to prevent those from

11 1 being recontaminated. So we want to clean it 2 up, and we want to make sure it stays clean. We 3 outlined a sediment clean-up goal of 4 19-milligrams per kilogram, which is the state 5 standard. We put forth a proposed plan out of 6 three different alternatives. The first 7 alternative was no action, which is required 8 under the Superfund process. It acts as a 9 baseline to compare the other alternatives 10 against. The second alternative was Ongoing Hot 11 Spot Excavation. The third alternative was 12 In-Situ Treatment, Hot Spot Excavation, 13 Performance Monitoring. 14 Alternative 1, not even going to talk 15 about anymore. Alternative 2, is Ongoing Hot 16 Spot Excavations. So we would periodically go 17 in and dig out the contaminated sediments. We 18 estimated approximated every three months we 19 have to dig up and dispose of them off-site. 20 Alternative 3, In-Situ Treatment, Hot Spot 21 Excavation, Performance Monitoring. The in-situ 22 treatment is going to be a chemical treatment in 23 place. We can implement this remedy without 24 having to remove the media that we're treating. 25 So with this remedy, we would sort of do a

12 1 surgical approach and apply in-situ treatment, 2 excavation, and monitoring in all of the areas 3 in order to effectively clean up the sediment. 4 So we would go in and, you know, sometimes we 5 might have to do excavation up front in order to 6 clean up some already contaminated sediments, 7 and then we would implement in-situ treatment to 8 prevent them from becoming contaminated, and we 9 would do some monitoring to make sure that it 10 doesn't become recontaminated. 11 So we took those three alternatives and 12 we compared them against nine criteria that are 13 in Superfund process. The first two, and the 14 most important, are overall protection of human 15 health and the environment. Second, is 16 compliance with applicable or relevant and 17 appropriate requirements, which are state and 18 federal laws. Then we look at the balancing 19 criteria, long-term effectiveness and 20 permanence, reduction of toxicity, mobility, or 21 volume through treatment, short-term 22 effectiveness, implementability, is this 23 technically feasible, and of course, we look at 24 cost. Lastly are the ongoing criteria that we 25 look at, which are state acceptance and

13 1 community acceptance. We always want the state 2 to agree with our remedy, and we always want the 3 community to agree with our remedy. We went 4 through that process and we determined 5 Alternative 3 to be the most effective 6 treatment, which is in-situ treatment, the 7 excavation, and the monitoring. 8 This satisfies the two important 9 threshold criteria, achieves the best 10 combination of all five of the balancing 11 criteria, and achieves our remedial action 12 objectives and our community goals. So, again, 13 to touch on in-situ treatment just to make sure 14 everyone understands, these are technologies 15 that are place. Some examples of those would be 16 air sparging, injecting air into the ground, 17 other chemical injections, PH adjustments, 18 reactive barriers. The final such of the type 19 of technology that we use will be made after we 20 do further studies and more testing throughout 21 the remedial design phase. As we learn more 22 about the site, we will identify exactly what 23 type of treatment technology we need. 24 So the next steps are to sign the Record 25 of Decision, develop remedial action plan,

14 1 implement the remedy. Hopefully, all that will 2 go well. Then we are going to eventually look 3 at other contamination that is part of the 4 Vineland site. We might need to re-evaluate the 5 groundwater. We're going to look at Union Lake 6 downstream, and we're always monitoring Maurice 7 River. So public comment period lasts through 8 August 22nd. You can write comments to me 9 specifically. My address and e-mail are on the 10 website and they're on the proposed plan. We 11 will also accept comments in this meeting 12 verbally or written. That's all. Any 13 questions? 14 WANDA AYALA: Comments? 15 HUNTER YOUNG: Thank you. 16 WANDA AYALA: The meeting is adjourned. 17 Thank you so much for coming. 18 - - - 19 (Whereupon, the hearing was concluded at 20 approximately 6:55 p.m.) 21 - - - 22 23 24 25

15 1 CERTIFICATE 2 - - - 3 4 I hereby certify that the witness was duly sworn 5 by me and that the deposition is a true record 6 of the testimony given by the witness. 7 8 9 10 ________________________________ 11 KATE M. REGENSBURGER Professional Court Reporter 12 Notary Public 13 14 15 (The foregoing certification of this transcript does not apply 16 to any reproduction of the same by any means, unless under the direct control and/or 17 supervision of the certifying reporter.) 18 19 - - - 20 21 22 23 24 25

Attachment D

Written Comments

1

Young, Hunter

From: Jones Dale <[email protected]>

Sent: Tuesday, August 09, 2016 3:39 PM

To: Young, Hunter

Cc: Mayors Office; Fanucci Anthony R; Tonetta Richard; Dickinson(Health) Robert; Dickenson

Bob; Lopez Emma

Subject: Vineland Chemical Company Super Fund Site

Hunter,

Please accept this email as comment to the EPA’s proposed plan to amend the approach to remediate contaminated

exposed sediment/soil of the Blackwater Branch floodplain that is associated with the Vineland Chemical Company

Superfund site located in Vineland, New Jersey. I was in attendance at your August 8, 2016 public meeting which was

held at City Hall regarding this matter. During this meeting you discussed the remedial action objectives and three

remedial alternatives in addressing the contaminated sediment/soil in the floodplain of the Blackwater Branch.

Presently there is groundwater that is discharging in the Blackwater Branch in certain areas and is recontaminating the

sediment within the floodplain of the Blackwater Branch. I support the EPA’s decision to use alternate #3 which is the in-

situ treatment, hot spot excavation and performance monitoring as an amendment to the original plan. Hopefully this

alternative will provide a more permanent solution to the area being recontaminated. The in-situ technology will be

monitored and adjusted as needed which makes more sense than constantly removing the soil/sediment each time it is

recontaminated and not addressing the source.

Respectfully submitted.

Dale Jones

Health Director

Vineland Health Department

640 E. Wood Street, Vineland NJ 08360

P]856-794-4000 *4115

F]856-405-4608

E][email protected]

Visit our website at www.vldhealth.org

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